On January 29, 2013, New Mexico joined Vermont, Massachusetts and North Dakota and became the fourth state this year, the tenth overall, to propose legislation requiring regular use of the Social Security Administration Death Master File (SSA DMF). However, as with the other states, New Mexico was not specific about what level of matching is sufficient with regard to ‘fuzzy’ logic. The lack of specificity regarding the undefined standard that insurers must meet is a cause for concern. It is critical that the industry understands the ‘minimum standard’ that will be acceptable for each state. In the interim, best practice is to take a conservative approach and apply the proven fuzzy logic that has been drawn directly from the various Global Resolution Agreement (GRA) and Regulatory Settlement Agreement (RSA) documents. By applying (and enhancing where possible) rules modeled from the consistently high standards that have already been accepted by numerous states, insurers better position themselves as follows:
- They demonstrate an intent to comply by using well-defined and documented business rules.
- They apply a consistently high standard for all states (as compared to varied rules for each) which is both easier to manage as well as erring on the side of caution.
- They proactively identify and resolve policies reducing exposure in a “Business As Usual (BAU)” environment using the more sophisticated processes typically required during an audit.
Cross Country Computer continues to monitor the landscape and alert the industry of the latest activity.
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