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Section 401 Data Call FAQ
Updated 06/11/2025
Frequently Asked Questions
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Why is DIFS issuing a data call?
Data is being collected to fulfill the requirement from the DIFS budget for FY 2025, Public Act 121 of 2024, article 7, part 2, section 401, requiring DIFS to study and report on the effects of the 2019 automobile insurance reform. The information provided will be used to determine the impact of the reform.
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What is the deadline for supplying the requested data?
The deadline for supplying data is June 16, 2025.
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Where do we send questions regarding the data call?
Questions may be sent to the email address DIFS-PA21-22@michigan.gov.
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How do we submit the data?
DIFS is using Egress to facilitate document transmittal. DIFS must register individual users for access to Egress. You may send questions regarding access to Egress to the email address DIFS-PA21-22@michigan.gov.
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What types of vehicles are covered by the data call?
This data call only covers private passenger type vehicles (and specifically does not cover antiques, motorcycles, ATVs, etc.). If a company does not write policies covering private passenger type vehicles, they can notify us, and we will consider that notice as their response to the data call.
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Should reported counts include claims closed with $0 payout?
Yes, reported counts should include claims with no payment.
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Should PIP medical and PIP work loss be combined in PIP data reporting?
Yes, report PIP medical and PIP work loss on a combined basis within PIP data. Count exposure once per policy (use maximum exposure between the two coverages or an alternative method to prevent double-counting). For events triggering both PIP medical and PIP work loss coverage, report only one claim count.
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Is “named insured” refer to the primary policyholder?
Yes, “named insured” refers to the primary policyholder.
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Which garaging ZIP code should be used for PIP claims involving non-policy VINs (e.g., accidents in rental cars or other vehicles)?
Use the ZIP code from the insured's mailing address.
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Does the data call include commercial lines?
No, the data call only covers private passenger auto coverages.
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Does "fee schedule savings" encompass both Medicare fee schedule and chargemaster?
Yes, “fee schedule savings” includes all savings compared to what the insurer would have paid before the reform. This includes all savings realized through the fee schedule in Section 3157 of the Insurance Code (MCL 500.3157).
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How should D&A incurred loss fee schedule savings be reported if gross MCCA data isn't available?
If data gross of losses ceded to MCCA or external reinsurers is unavailable, report as missing (0.00).
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Does "Excess Attendant Care (XS Att Care)" mean the post-reform attendant care rider?
Yes, this refers to the attendant care rider for coverage of attendant care that exceeds an insured's PIP limit. See MCL 500.3107c(8).
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What components comprise PIP, and should counts be reported on a per-claim or per-claimant basis?
PIP includes medical expenses, lost wages, attendant care, replacement services, medical mileage, home & vehicle modifications, and survivor's loss benefits. Counts should be reported per claim, not per claimant.
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Should claims closed without payment be included?
Yes, include claims closed without payment.
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How should claim-free rewards and COVID premium refunds be handled?
Report premiums net of claim-free rewards and COVID premium refunds.
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Should collision coverage types (broad, basic, limited) be combined?
Yes, combine all collision types in reporting. Do not report broad, basic, and limited separately.
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Should miscellaneous coverage premiums be included in total premium?
No, exclude premiums for car rental, extra equipment, guaranteed asset protection (GAP), total loss replacement, and other miscellaneous endorsements from the total premium.
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Do we need to include rate filings solely for MCCA/regulatory changes?
No, only include rate filings that have a direct impact on customer rates. Exclude MCCA assessment-only changes, forms filings, rule filings, or any regulatory change filings without rate impact.
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What evaluation date should be used for accident year data?
All accident years should be evaluated as of March 31, 2025.
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In File #3, should “Age of Named Insured” be based on the date of loss or something else?
All data should be aggregated by the age of the named insured at the policy's effective date, not the claimant's age.
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In File #4, should gender be recorded for the insured or the claimant?
All data should be aggregated based on the gender of the named insured, not the claimant.
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In File #4, should marital status be based on the date of loss?
Since not all policies will have claims, please use the marital status of the named insured at the effective date of the policy period.
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Should savings calculations include premium reductions or just fee schedule changes?
Only savings from the fee schedule change should be included. Reductions due to additional limits offered should not be included.
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How is “car years” defined?
Car years should be defined as the proportion of the year during which a policy is in effect for a vehicle.
- If a vehicle is insured for a full calendar year, its earned car years = 1.0.
- If a vehicle is insured for a semi-annual policy term, its earned car years = 0.5.
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How should age be grouped when rating by household?
If rating is based on household age, please use the maximum age in the household.
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How should we report gender if it is not used for rating?
If gender is not available in the data, it should be summarized and reported as “Missing” in the Gender of Named Insured field.