A Checklist for Compliance National PHI Code of Conduct Seminar 21 July 2015 Presenter: Christine Mead Senior Compliance Manager Medibank Private

Background Recent Audits of Health Funds have identified the propensity for non compliance in:  Website content  Mobile App’s  Marketing Brochures & Collateral WHY?  Disconnect between Compliance and Marketing Departments  Uncertainty of Code Self Audit requirements  Uncertainty of compliance requirements under the Code Compliance with PHI CoC

Compliance with the PHI Code enhances the following:  Improved business outcomes  Enhanced customer experience  More informed customers  Greater customer loyalty  Less formal complaints to the Ombudsmen  Reduced complaint investigation time and resources Why Comply?

The PHI Code of Conduct specifies two key types of information: 1.Product Sales Material (product summaries) 2.Policy Documentation The two are quite different and the ‘disconnect’ occurs because:  Marketing and Sales not working from a requirement list; and  The Self-Audit Guide does not contain a specific requirement to demonstrate a process of compliance The ‘Disconnect’

Product Sales Material (product summaries) must accurately reflect the cover being offered and is defined in the Code as: ‘Material that markets or promotes a PHI Fund, PHI Policy or PHI Product of a PHI Health Insurer that is not Policy documentation, whether in printed or electronic form’. Product Sales Material

Policy documentation requires the inclusion, as a minimum, of accurate information on 15 separate items as identified under the Code and is defined as: ‘Private Health Insurance Product policy wording, fund rules or similar PHI Policy information, in any printed or electronic form’. Policy Documentation

The ‘Disconnect’ occurs when:  Important policy or product information is omitted  When de-cluttering information – particularly on websites  When trying to be creative with marketing  When endeavouring to simplifying information for customers. This results in Marketing or Promotional material that is not compliant with the Code and, when identified, can result in reproduction and a costly exercise to replace. How does the ‘Disconnect’ occur?

Product Sales Material –what is it? A SUMMARY – but must be accurate! Waiting Periods Restrictions Exclusions BLP Excesses & Co-payments Annual Limits Pre-existing Conditions These must be Detailed  These must be mentioned with a link to the detail

Policy Documentation – what is it? The DETAIL Waiting Periods Restrictions Exclusions BLP Excesses & Co-payments Provider Information -Hospitals -No-gap doctors -Recognised providers Complaints Handling Annual Limits Cooling Off Read & Retain Privacy Code of Conduct And Code Logo Pre-existing Conditions

To assist all funds we have provided a detailed document available via the download section of the PHA website at gin/ A ‘Checklist’ to Assist

Questions?