9 - Consumer Service

9.1 Mission

The Consumer Services Section (CSS) responds to inquiries and assists consumers in resolving complaints against insurers, producers and other licensees. In addition to providing consumers with general insurance information in the form of brochures and guides, the Section also advises consumers on their options and rights under their policies, state laws and insurance regulations.

9.2 2008 Goals

Hire and train new staff to replace four examiners that left the Division in 2007. Workloads and all outstanding cases left by exiting employees to be reassigned to the remaining examiners. Close outstanding cases from departed examiners.Complete
Create an Administrative Guide to complement the already completed Administrative Flowchart to assist all existing temporary or permanent assistants with on-the job training and resources.Complete
Continue on-going training for existing and newly hired CSS staff on insurance topics in areas of property & casualty insurance, underwriting, and claims handling available through the Insurance Library in order to better assist the public.Complete
Maintain and schedule monthly training sessions for CSS staff offered by the State Rating Bureau to cover topics in areas of health care reform and the current status of the competitive auto market affecting consumers.Complete
Enhance monthly CSS productivity reports submitted to Senior Staff by highlighting key factors of call and case trends.Complete
Increase the number of case referrals to Special Investigations Unit (SIU) and enhance examiner's knowledge by implementing internal training from SIU in order to comply with the department's mission of tracking and reporting market conduct issues.Complete

9.3 Primary Activities

Consumer Calls

Insurance consumers receive personal assistance from the Division's Consumer Services staff by calling the Consumer hotline Monday through Friday 8:45 to 5:00. All hotline calls are logged into a call database. This database allows the Division to gather a range of sortable data on each call. CSS runs a variety of reports based on this data in order to show trends in consumer hotline calls. Examiners answer questions regarding most lines of insurance and offer information about companies and producers, such as the status of licenses and complaint data. Consumer Services staff refer callers to the materials on the InsureMass section of the Division's website in order to provide deeper background on the question or complaint.

In addition to informational requests, approximately one in ten calls to the hotline is a consumer complaint. Examiners are often able to resolve such complaints over the phone with a simple verbal explanation of the relevant insurance law or contract provision. In other cases, Consumer Services staff recommend that the caller file a formal complaint to the Division. In the fall of 2008, the Section's call volume increased significantly due to questions from policyholders of the AIG Insurance Company. When news stories broke about the possible failure of the AIG parent company, consumers across the nation feared for reliability of policies purchased from AIG insurance subsidiaries. In the first week alone, the consumer hotline received nearly 150 calls on this topic. AIG policyholders wanted to know whether the company was solvent, and what protections existed if the crisis resulted in an insurer insolvency. CSS examiners were able to explain the basic elements of the Massachusetts Life and Health Guarantee Fund and referred callers to the Fund for more detailed responses.


2008 Consumer Informational Calls Top 5 Reasons by Line of Insurance
Automobile Insurance Health Insurance
Claim Settlement TimeframeContinuation of Coverage
Premium RatesMandatory Benefits
CancellationsMini-COBRA
Safe Driver Insurance Plan (SDIP)Co-payments
SR-22sClaim Settlement Timeframe
Home Insurance Life Insurance
CancellationLicense Status
Claim Settlement TimeframeClaim Settlement Timeframe
Non-renewalInterest
CoinsuranceCancellation
Determine ACV# of Complaints Against Company
Consumer Complaints

Any consumer of an insurance product marketed or sold in Massachusetts may file a consumer complaint with the Consumer Services Section against an insurer or insurance producer. Written complaints are entered into our database and then forwarded to the company or producer for response. Licensees must respond to the Division within 14 days with a complete reply addressing all issues raised in the consumer complaint. Section examiners review the complaint and licensee reply, and advocate for the rights of consumers where appropriate. Closed complaints are coded in the complaint database The complaint database provides for both proper case management and the reporting of complaint data. In order to protect the insurance public and accomplish the Division's mission of forecasting trends regarding the insurance industry, the section generates monthly reports from the complaint database. These reports allow the Division to look for patterns of unfair or deceptive practices by producers, insurance companies, or other licensees. When appropriate, the information may be referred either to the Special Investigations Unit or Market Conduct Section for further action. "Slow pay" patterns and other questionable industry trends are brought to the attention to the Division's Financial Surveillance staff, as these may be early indicators of liquidity or solvency problems.


Over the last several years, the Division has invested significant time and resources in the training and development of the Consumer Services staff. Along with training in key content areas, the Section also conducted a series of internal strategic planning sessions aimed at maximizing the quality of complaint reviews. For the second consecutive year, the section secured a substantial increase in recoveries for consumers. In 2008, CSS staff resolved over 1500 written complaints and recovered more than $1.4 million for consumers.

Complaint Dispositions

The vast majority of complaints with positive outcomes result in dollar recoveries for consumers. While they are very important, these recoveries are only one of several possible favorable resolutions for a consumer complaint. In many cases, consumers complain to the Division because their insurance company is unresponsive or slow in settling a claim. Such cases typically involve a delay resolution in addition to a recovery. In other cases, the Section assists consumer working to restore policies, rescind cancellations or waive fees.

Complaint Response Time

The top priority of the Consumer Service Section is to find the correct answer to consumer questions and complaints. The Division places more importance on accuracy than on speed. Nonetheless, the Section recognizes that timeliness is an essential element in the proper handling of a consumer complaint.

In many cases, consumers have already experienced a substantial delay in the resolution of their dispute with the insurer before a complaint is filed with the Division. Claim denials and policy cancellations leave consumers in a financial limbo - they cannot move forward or back without a definitive answer on an unresolved insurance dispute. The staff of the Consumer Service Section has the goal of resolving each consumer complaint in 90 days or less. For most of 2008, Consumer Services operated at a level between 65% and 85% operational capacity due to the departure of several experienced examiners in late 2007 and several staff absences in early 2008. Despite these structural limitations, Section staff doubled the percentage of cases handled in less than 90 days over the course of the year.

Complaint Ratios

Among the thousands of questions posed by consumers calling the Division's hotline concerns the reputation of particular insurance companies. Consumers shopping for coverage often look for some objective measure of customer service on the part of specific companies. Each year, the Division posts updated complaint ratios for major insurers in the private passenger automobile and homeowner's insurance markets. The ratios are calculated by comparing the share of complaints filed against a company to that company's market share. This figure is then normalized to a ratio per $10 million in premium written in order to control for different levels of market share. In 2008, the Consumer Services Section handled nearly 600 automobile insurance complaints. Twenty-two auto insurers wrote at least $10 million in premium in Massachusetts during 2008.

2008 Private Passenger Automobile Insurance
Complaints and Market Share
Company Premium Share in 2008 Complaints Filed in 2008 Complaints per $10,000,000 in Premium
Commerce Group 31.00% 169 1.47
Safety Group 11.05% 68 1.65
Arbella Insurance Group 9.25% 35 1.02
Liberty Mutual Group 8.37% 48 1.53
Metropolitan Group 6.53% 51 2.10
Travelers Group 6.28% 50 2.14
Plymouth Rock Assurance Corporation 5.88% 30 1.37
Hanover Insurance Group Allmerica Financial 3.84% 28 1.96
Amica Mutual Group 3.62% 21 1.56
White Mountains Group 2.49% 16 1.71
United Services Automobile Association Group 2.12% 5 0.63
Allstate Insurance Group 2.11% 12 1.53
Quincy Mutual Group 1.67% 6 0.97
Main Street American Group 1.26% 4 0.86
Progressive Group 1.24% 19 4.12
Norfolk & Dedham Group 1.12% 6 1.44
Allianz Insurance Group 0.48% 7 3.91
Pilgrim Insurance Company 0.48% 8 4.49
State Farm Group 0.42% 1 0.64
Electric Insurance Group 0.40% 4 2.69
Remainder of Market (13 Groups) 0.39% 11 7.67


The number of consumer complaints regarding homeowner's insurance is significantly smaller than the number of automobile insurance complaints. In order to ensure that comparisons between companies are valid, the Division groups together homeowner's complaints from a five year period: 2004 -2008. Unlike the automobile insurance market, the homeowner's insurance contains a large number of carriers with comparatively small market shares. In calculating complaint ratios, the Division looks at the top 25 company groups and the Massachusetts Property Underwriting Association (FAIR Plan).

2004 - 2008 Homeowner's Insurance Complaints and Market Share
Top 25 Company Groups & Fair Plan Premium Share 2004-2008 Complaints Filed 2004-2008 Complaints per $10,000,000 in Premium
MA Property Underwriting Association (FAIR Plan) 12.73% 146 1.36
Commerce Inc. Group 8.71% 80 1.08
Andover Group 7.35% 42 0.68
Travelers Group 6.86% 53 0.91
Chubb & Son Inc. Group 6.73% 4 0.07
Liberty Mutual Group 5.88% 37 0.74
Quincy Mutual Group 4.96% 37 0.88
Arbella Insurance Group 4.50% 39 1.02
Vermont Mutual Group 3.33% 22 0.78
The Hanover Insurance Group 2.88% 11 0.45
Safety Group 3.02% 24 0.94
Metropolitan Group 2.29% 19 0.98
Amica Mutual Group 2.63% 9 0.40
Norfolk & Dedham Group 2.59% 12 0.55
White Mountains Group 2.35% 16 0.81
United Services Automobile Association 2.24% 3 0.16
Plymouth Rock Insurance Group 1.90% 12 0.75
Hingham Mutual Group 1.68% 20 1.41
Preferred Mutual Insurance Company 1.64% 26 1.87
Allianz Insurance Group 1.39% 3 0.26
Barnstable Group 1.43% 2 0.17
Main Street America Group 1.24% 5 0.48
Providence Group 1.09% 10 1.08
Union Mutual Fire Insurance Group 0.95% 4 0.50
Harleysville Group 0.95% 8 1.00
New London County Group 0.95% 6 0.74





9.4 Special Activities

Section staff participated in two successful consumer outreach events in 2008. In February, 2008, the Division set up a consumer day in the lobby of South Station. This event accompanied the transition to managed competition in automobile insurance. Governor Patrick addressed a crowd of spectators while CSS staff assisted the public in navigating the Division's two new web-based tools for auto insurance shopping: AgentFinder and the Sample Premium Comparison site. The second event was a similar demonstration at the Roxbury Film Festival held during the first week of August. Section staff assisted consumers by demonstrating our online services and providing general insurance information and brochures about auto, health and life insurance.


9.5 Consumer Services Section Statistics

9.5 Online Consumer Publications

As part of their mission to provide insurance consumers with accurate and useful informational materials, the Division creates, updates and publishes a range of insurance materials in print and online. These materials must find a way to explain relatively complex insurance topics in a manner easily understood by the average consumer. Every publication created and maintained by the Division is also posted on our website. Below is a list of consumer publications and web pages available as of December 31, 2008.

Automobile Insurance

  • It Pays To Shop Around (Consumer FAQ)
  • Massachusetts Consumer Bill of Rights for Auto Insurance
  • Massachusetts Auto Insurance Plan (MAIP) Consumer Guide
  • Ways to Save on Your Auto Insurance 2008
  • FAQ on Auto Insurance
  • Automobile Group Marketing Plans (Group Discounts)
  • Safe Driver Insurance Plan (SDIP) - How SDIP Works, Appealing Surcharges, & Hearing Locations
  • How to Appeal Your Driver's License Revocation
  • How to Appeal an Auto Insurance Cancellation
  • List of Companies Writing Automobile Insurance in Massachusetts
  • Automobile Insurance Consumer Complaint
  • Motor Vehicle Insurance Installment Plans

Homeowner's Insurance

  • Commissioners Report on Homeowner's Insurance
  • National Flood Insurance Program
  • FAQ on Homeowner's Insurance
  • Homeowner Group Marketing Plans 2009 (Group Discounts)
  • Homeowners Warranty Contracts
  • MAHA Homesafe Program & Discounts
  • Homeowner Insurance Service Areas
  • Companies Writing Home Insurance in Massachusetts
  • Consumer Alert: Renter to Owner
  • A Massachusetts Guide to Insurance for Your Home and Ways to Help Reduce Your Insurance Premiums
  • A Massachusetts Guide to Understanding the Insurance Policy Covering Your Home
  • FAQ on Flooding and Insurance

Health Insurance

  • Health Care Reform Tips and Resources
  • Consumer Guide to Health Care Coverage
  • Consumer Guide to Individual and Small Groups
  • Employer FAQ on Non-discrimination and Equal Contribution Requirements
  • Long Term Care Guide
  • Mandatory Benefits Guide
  • Medigap/HMO Guide Effective
  • MiniCobra Continuation of Coverage Benefits Guide
  • Consumer Alert: Be Aware of Unlicensed Health Plans
  • Consumer Alert: Premium Assistance for Employees of Small Employers

Life Insurance

  • Buying Life Insurance and Annuities in Massachusetts
  • Consumer Alert: Annuities and Senior Citizens

Workers Compensation Insurance

  • Workers Compensation FAQ for Employees
  • Workers Compensation FAQ for Employers

Miscellaneous Insurance Guides

  • Renter's Insurance
  • Credit Insurance
  • Boat Insurance
  • Recreational Vehicle Insurance
  • Travel Insurance
  • Pet Insurance
  • Wedding Insurance
  • Winter Weather Insurance
  • Identity Theft
  • Insurance Fraud
  • Disaster Information