For the last four years, the Federal Insurance Directorate (FID) has approached policyholder claim appeals through the lens of the customer experience work started in 2017. During this time, the team recruited and trained talented staff, implemented iterative improvements to the appeals process, and used data to inform future areas of concern and opportunity. With a fully-staffed appeals branch to start 2021, we continue to refine our process and software to generate more efficient interactions with Write Your Own companies and policyholders.
In Fiscal Year (FY) 20, FID completed a total of 930 appeals and closed 518 more appeals than it received, ending with an average of 18.24 appeals completed per week. For FY20, 14.3% of policyholders with eligible appeals received a different claim outcome on appeal. To date for FY21 (as of Feb. 1, 2021), the branch has completed 176 cases while receiving 152 cases, and 16.8% of policyholders have achieved a different outcome on appeal.
Of note, the appeals branch received 82 ineligible appeals in FY20 and 26 so far in FY21. We conservatively estimate that every ineligible appeal takes an average of 45 minutes of combined staff time, between determining eligibility, data entry, populating response templates, requesting missing documents from policyholders when applicable, and ultimately finalizing and mailing the ineligibility letter. That means for FY20 and FY21, the branch spent over 80 hours of staff time on ineligible appeals. FID intends to reduce this number through an Appeal Form, included in the next package of National Flood Insurance Program Claims Forms (OMB Control No. 1660-005). The form uses date formulas and check boxes to confirm the eligibility of the appeal, prompt for missing information, and return an immediate result to the policyholder. This small improvement will help the policyholder and allow the staff more time to focus on eligible appeals.