District of Columbia-SIU Requirement-Bulletin 99-FR-001-5/1 Attachment 3

Recommendations for the Development and Application of the D.C. Insurance Fraud Prevention and Detection Plan C. Employment of fraud investigators: D.C. Code 22-3825.9 (a)(3) The anti-fraud plan should contain specific procedures for determining who should conduct or oversee such investigations. You should analyze your options to maintain an in-house staff of investigators or contract with an outside firm.

Sec. 6 Antifraud initiative requirements The antifraud initiative requirements of Arkansas Code Annotated Sec. 23-66-510(a) may be satisfied by an insurer by means of: (1) Fraud investigators, who may be insurer employees or independent contractors and who are in full compliance with Section (7) of this rule; or (2) An antifraud plan submitted to, and approved by, the commissioner, and which is in full compliance with Section (8) of this rule; or (3) An alternative antifraud initiative submitted to, and approved by, the commissioner, under the provisions of Arkansas Code Annotated Sec. 23-66-510(a); or (4) An exemption from the antifraud initiative requirements granted by the commissioner pursuant to Arkansas Code Annotated Sec. 23-66-510(b). Sec. 7. Fraud Investigators and independent contractors A. Fraud investigators who are employees of an insurer: (1) shall be qualified by education, experience or training in the detection, investigation and proper reporting of suspected fraudulent insurance acts, and may be employees whose principal responsibilities are the processing and disposition of claims, if they meet the qualification requirements herein stated; and (2) shall complete a minimum of three (3) hours of continuing education annually in the detection, investigation and proper reporting of suspected fraudulent insurance acts. The specific curriculum, location and certification of said continuing education courses are not mandated but shall be consistent with industry standards for continuing education for insurance fraud investigators.