A New Model for No-Fault and Workers’ Compensation Insurance Posted on:4/18/2013
Written By: Frimette Kass-Shraibman
|The current system of no-fault and workers’ compensation is broken. It is rife with fraud! In order to protect against fraud the insurance carriers over-aggressively deny coverage. True victims of accidents are therefore unduly denied coverage. This paper suggests new system for dealing with care, payments and fraud detection in the no-fault and workers’ compensation arena.
“The modern system of workers’ compensation is so complex and arcane it produces considerable grief to those who must deal with it on a daily basis. Yet these often cumbersome regulations are so ultimately vital to society, they appear, in one form or another, in all industrialized nations.”
(Guyton 1999, 106-107-110)
Based on my awful experiences with no-fault auto insurance I kept thinking that there had to be a better way to do this. After long and careful consideration of the issues related to no-fault auto insurance I created a new model. I believe that this model, if implemented, has the potential to protect insurance companies from fraud while still affording quick, quality medical care to true victims.
Although personal experience with no-fault is the inspiration for this paper I include workers’ compensation insurance in the model. They have similar problems and issues and I believe can be cured with the same pill.
What is no-fault and workers’ compensation insurance?
Both no-fault insurance and workers’ compensation have long histories. They both stem from attempts at social justice and responsibility. They have had many changes over the years. Here is a brief history of both.
A brief history of workers’ compensation insurance.
Workers’ compensation (Harger 2011) insurance is an ancient social construct. Some historians find evidence of it in China at around 3000 B.C.E. (Harger2011, Lloyd 2011). Other historians have found evidence of workers’ compensation insurance in the city of Ur on the Fertile Crescent at around 2050 B.C.E. (Guyton 1999, 106-107-110). Tablets of the king of Ur have been found that have lists of monetary damages for specific body parts. Similar records have been found for Ancient Greece, Arabia, and Rome.
In more modern times there was a major evolution of workers’ compensation with the advent of the industrial revolution. Harger (2011) reported that Germany passed legislation in 1838 protecting railroad workers. In 1880 England passed the ‘Employers’ Liability Act.’ That together with an overabundance of solicitors caused a major back log in the courts. The solicitors learned that under this act they could successfully sue employers for injuries. There were so many cases that the courts were in a state of gridlock. This led to repeal of the ‘Employers Liability Act’ in 1897 and its’ replacement with a workers’ compensation law.
The attorneys in the United States saw what was happening in England and they too began commencing suits against employers for injuries to workers. In 1908 President Theodore Roosevelt urged passage of the first federal workers’ compensation legislation. This landmark law covered federal employees and those involved in interstate commerce (Harger, 2011).
Wisconsin passed the first comprehensive state workers’ compensation law in 1911. The innovative in this law was that covered employees would not be allowed to sue their employers (Harger 2011). By 1948 all the states and the ‘stated-to-be- of Alaska and Hawaii had some form of workers’ compensation law.
A brief history of no-fault insurance.
No fault auto insurance has its roots in academia in the 1930s. With the rise of the use of the automobile there was also a rise in accidents and of course, too many lawyers. In order to lower the exposure of the insurance companies some professors suggested that it would be more economical for the insurance carriers, and better for injured parties, if the insurers would just pay for injuries without going through the process of litigation to assess fault (Anonymous2005). A major revision came in 1965, when two academics suggested that any auto accident victims be required to accept no-fault benefits if their loss was below $5,000. Others would still be permitted to avail themselves of the courts for adjudication (Anonymous2012).
The construction of this paper
In this paper I will describe the problems with the current system. I will tell my story as one example of some of the problems with this system. I started to develop this paper based on my personal experience.
This paper, however, is not my own. I have spoken with a number of health care providers that provide services under the no-fault program. They have described to me horror stories from their perspective. They have seen patients cut-off from services as a result of bad insurance medical exams (IMEs), been paid late, or not at all, by insurance companies trying to play fiscal games, lied to by phony patients or real patients trying to squeeze more out of the system then to what they were entitled, and pressured by bosses who own mills to generate more income. Some have read and critiques this paper in its various stages of development. Each of these people asked not to be named as a co-author, contributor, or interviewee for fear of having their income reduced. I thank all of them for their contributions.
Throughout the paper I use the terms victim and patient interchangeable. It depends on which description fits better in a particular situation. People become victims of auto accidents, then become patients, and then become victims of the system. Generally health care providers refers to those trying to heal the patient victims and IME providers are those health care professionals that work for the insurance companies to determine the necessity of the health care being provided.
The motivation: My story
In April of 2010 I was involved in a car accident. I was driving my daughter’s car, a 2002 Chevy Malibu. I was making a right turn at low speed. I stopped for a schoolchild in the crosswalk and was hit in the rear by Jeep. I immediately felt pain all up and down my back. I asked, and was taken to a nearby emergency room (ER). That’s when I started becoming a continual accident victim. The ER staff told me I did not have any major injury just a little whiplash. I was told to go home and take pain killers. My thought was that a little whiplash is best dealt with by chiropractic and acupuncture. Since I already had the acquaintance of these professionals I immediately made appointments. I thought that with a few months of treatments I’d be good as new. Boy! Was I wrong!
After several months of treatments I was still in pain. I was sent for an MRI of the shoulders. I took the report, which was not well written, to an orthopedist who added physical therapy to my regime. When I was still in pain, a few months later, he sent me for surgical consults. The shoulder surgeon I saw actually looked at the MRI films and found that I had a fully torn rotator cuff which is only ‘cured’ by surgery. The neurosurgeon sent me for and MRI of the cervical spine which showed herniated disks and spinal stenosis, both causes of pain. What ensued was more therapy and more therapy: chiropractic, acupuncture, massage, and physical therapy.
I did therapies multiple times a week in the hopes of alleviating pain and returning to my old self. I had been very physically active before the accident. I tried to keep up afterwards but some things had to go. I could no longer go to the gym. My efforts at tai chi became comical. I did go to work throughout. However, I had to have help from my students. They lugged books back and forth to the classroom and did the board writing for me as I winced with pain. My research agenda fell behind where I wanted it to be. For three months after the surgery I could not drive or take public transportation on my own. I had to rely on government supported transportation for the disabled.
At some point the insurance company needed to contain costs, understandably. They started sending me for ‘Insurance Medical Exams’ (IME). Anecdotal evidence suggests that the healthcare providers ding IMEs are (a) not the best of providers (if they were better they’d have full-time practices of their own) and (b) skew their opinions to the benefit of the insurance companies who put the bread on their table. I spent hours waiting in the offices of hacks, having my HIPPA rights violated, being given cursory, almost non-existent exams, only to be told the insurance company would no longer pay for services. At least twice I cowered while fight broke out in the halls of IME mills. Then I spent hours crying, writing letters to state professional boards that went unanswered and fighting with the insurance company. I kept thinking that there had to be a better way!
Whys and wherefores of IMEs
The insurance companies require the victims of car accidents and work injuries to be examined by the insurance carriers designated health care providers. The purpose of this examination is to determine if the patient/victim (claimant) actually needs the services being provided. If the examiner determines that the patient victim does not need the care s/he writes a report to the insurance company. The insurance company then sends a notice to the claimant that benefits are being denied. Usually the denial is retroactive to the date of examination. Therefore if the examiners or the insurance carriers are tardy with their reports the claimant may be continuing to receive services that will not be paid by the insurance company. The claimant does not have the opportunity to decide if they will continue to receive services and self-pay. There’s got to be a better way!
In New York State any health care provider that agrees to accept no-fault insurance also agrees to be paid for their services based on a set fee schedule (Anonymous2006). If the claimant sees an out-of-state provider they can charge whatever they want. The insurance company is obligated to pay. Often providers in this type of situation charge exorbitant amounts. (My carrier was billed $500 for an acupuncture session and $300 for a physical therapy session by providers in Florida. Had I known I probably would have stayed home or been more inquisitive about fees before being treated.) It is therefore possible for a claimant to be liable for thousands of dollars of medical care without even realizing it. There’s got to be a better way!
The process of IMEs are arguable very inefficient. The claimant is being examined with the intent of being denied payment for care. The examiners are arguably not the best qualified. The entire process must be costing the insurance companies a lot of money. Why do it? Fraud!
Insurance frauds, and no-fault fraud, in particular, are big business and growing. Corum (Corum 2011) reported that in excess of 20 percent of the auto accidents reported in New York City in 2010 appeared to have a fraudulent element related to them. He further reported that “From 2007 to 2010, the percentage of no-fault claims in the New York City area with the appearance of claim abuse rose from 29 percent to 35 percent. (Para. 1)
In a required report to the governor and legislature of New York State, Financial Services Superintendent Benjamin Lawsky recently reported the following:
“Insurance: The CIU (Criminal Investigations Unit) recorded 703 arrests during 2011, with arrests for health care fraud (private health care, no-fault, and disability) totaling 210. A focus on workers’ compensation fraud increased arrests by 24.4% in 2011. The number of convictions obtained by prosecutors in CIU cases totaled 401 for the year. In addition the CIU received 23,433 reported of suspected fraud in 2011, no-fault fraud accounted for 11,974 or 51%. Court ordered restitution totaled $34 million for the year. Currently the CIU has 1,919 cases open for investigation statewide.” (Lawsky 2011)
Florida revised their no-fault insurance laws, in 2012, hopefully to reduce the amount of fraud. Fraud had been costing Floridians in excess of $1 billions year. (Anonymous2011)
Clearly fraud is an issue. If we can cut down on the amount, and costs, of fraud by revising how the insurance and health care industries handles patient victims then the honest insured drivers and their insurance carriers are sure to benefit.
There are many types of insurance fraud. Healthcare providers who are performing services that are not necessary or just billing fro services not provided, is a large part of the fraud. Sometimes victims try to take advantage of a situation and milk the carriers for all they can. The most egregious fraud is the staged accident. In this scenario a group of criminals will stage and accident, where the victims are part of the scam. They are connected to lawyers and health care providers that are also members of their posse. The victim of the staged accident is represented by a lawyer who is in on the scam and is take care of by providers who bill the insurance companies for everything possible and then some. The worst part of this scenario is that often innocent people also end up getting hurt, and even dying, when the accident happens.
All this fraud is very costly. The Consumer Watchdog inert cite has reported that auto owners, in states that have no-fault insurance, pay premiums that are approximately 19% higher than the rest of the nation.
Like I’ve said before: there has to be a better way. We need a system that will protect the insurance companies from fraudsters as well as get true victims the care they need. After much thought, and based on my observation of how things work now. I am proposing a new and different system. The ‘Frimette’ system of no-fault uses modern technologies in a way that will enhance care for accident victims and protect insurance carriers. It is large and complex. Implementation will be costly. However, in the long run, I believe, it will save the insurance industry millions, if not billions of dollars.
Central registration of accident victims
First, I believe that all accident victims should have to register in a central, nationwide, database. Through this database they will be assigned a claim number for their incident. In order to complete a registration, but not delay initial services, an insured may require that the victim provided substantiation of their identity such as government issue photo ID. Obviously this cannot necessarily be done in the emergency room nor should the absence of identification preclude the victim receiving emergency care. However, at some point, as soon as practical, the patient/victim should be required to produce identification to a provider or adjuster. The victim need not provide identification from the United States; it can be from any government. Having foreign ID, or not having ID should not preclude a victim from receiving services. However, the inability to produce proper identification should raise some red fraud flags.
Maintaining a master list of claimants will help insurance companies identify those that become victims more often then the usual and therefore might be fraudsters. Maintaining a master file of claimants will also help health care providers because they will have access to the claimants’ medical history, at least as it applies to the current, and previous, injuries. Those with excessive claims should be subject to scrutiny to determine the veracity of the current claim.
Likewise, any claimant that has a history of being successfully sued for fiscal malfeasance, or any similar crime, should be the subject of additional security.
Claimants are not the only fraudsters. A substantial number of the frauds are also committed by health care service providers. The new system needs to include ways to inhibit less than honest providers. Since there are issues with IME providers, also, those professionals that wish to be part of the IME pool should be subject to the same scrutiny as providers.
The first requirement for a provider to participate in no-fault is a valid license from the board/agency that regulates their profession. Furthermore, they must maintain good standing before the board/agency. If they have a requirement to maintain their professional knowledge, trough continuing education (CE) then participation in no-fault will require that they be up-to-date with their CE. In the event their professional board/agency does not have a CE requirement then the no-fault board shall establish such a requirement.
Any provider that has been successfully tried and convicted of a crime of fiscal malfeasance should be barred from being a no-fault provider.
It is a common belief that persons with low or bad credit are more likely to commit fiscal crimes. Therefore many potential employers run credit checks on job applicants and will not hire a person with credit issues. I was not able to find any literature that supports this theory empirically. However, the theory does make sense. Therefore, providers wishing to participate in the no-fault pool should be subject to a credit check. I don’t, however, believe that a poor credit score should bar a practitioner from participation. Sometimes bad credit does happen to good people and it would be wrong to deny a health care professional the opportunity to earn money by practicing health care. However, those providers with poor credit scores should be subject to more scrutiny just in case the theory is correct.
Some exceptions. There will need to be some exceptions to these rules. Emergency room doctors and hospital radiologists (and other specialists) provide care on the spot when an accident happens. It would be difficult to exclude them from participation. The next doc up handles the next patient that rolls in and there is not a way, that I have been able to think to, to get a round this. If a doctor is working in a hospital they are usually required to be board certified in their specialty, and therefore required to maintain their CE. Also, these doctors often do not do their own billing but the hospital does it for them and therefore fraudulent billing is less likely. These providers usually see the patient only once, at the time of the accident, and do not have prolonged care regimens with the patient.
For these providers fraud is less likely. However, by maintain a database of providers, that includes these doctors, will allow for statistical analysis that will uncover the anomalies.
The billing system is the key to this new model. I believe the billing system should be centralized in a manner similar to MasterCard or Visai. The various healthcare provides will submit their bills to and interchange which will then send the bill along to the appropriate insurance carrier. Because the billing will be centralized it will allow for statistics to be maintained.
I have not been able to determine if there is an average number of patients a provider should or can see in a day. Obviously this would vary based on specialty and how well the provider manages his/her practice. However by keeping all the billing in a central database it would be easy to develop statistics and then determine which providers were billing n-fault and workers’ compensation carriers for impossible numbers of patients. These providers should be the object of scrutiny.
I did hear about one chiropractor, in upstate New York, who actually sees 600 patients a day. I was told that he had the patient tables arranged in a big circle. Aides follow him as he goes from table to table. In between tables an aide reads from a chart to let him know what treatment should be given to the next patient; another aide records what he did to the last patients. Other aides help completed patients off the tables and new patients on to the tables. The doctor goes around the circle all day long. He actually does treat 600 patients, a day, and is therefore entitled to bill for these visits. From a patient perspective, however, I wonder about the quality of care.
Similar review should be given to IME provides. I have been sent to mills where IME providers are working for more than one IME service provider. They load up their schedules to see as many patients as possible. Often these are not their regular offices but mills that do only, or mostly, IMEs. The offices are crowded and noisy. You sometimes can not even get a seat in the waiting room. I have seen fist fights over seats, who is next, and perceived occurrences of being ‘dissed.’ This is a horrible and frightening experience – all to be able to get care for which I have paid and am entitled. Some examinations have lasted less than five minutes. Is it really possible for a health care professional to form an opinion on a complex case in less than five minutes? I was once seen by a chiropractor who was also supervising a physical therapy patient at the same time. The interchange would keep track of which IME providers are seeing more patients in a day than is reasonable and cause these providers to have extra scrutiny.
Side benefits of centralized billing.
There hare other benefits of this centralized billing system for patient care. Although this is not a medical record keeping system it may also be used by a health care provider to determine who the patient has seen before and why. If a patient says I think I already had an x-ray done on the knee the current provider could easily find out if, when and where the x-ray was actually done. Then a copy of the film and/or report can be ordered which is a lot less expensive and less dangerous than ordering another x-ray. Of course this would all be subject to HIPPA compliance.
Timeliness of billing and payments.
I have been told that sometimes providers play games with the insurance companies by withholding billing. They know that once an insurance company gets bills for patient care they start a clock to determine when to order the first IME. The companies also require that bills be submitted within a certain number of days of incurring the expense in order to be considered timely. The providers wait until the last possible timely day to send out the first bills in order to delay the start of the IME clock. This way, if they are providing unnecessary treatment, they more billing done before they are stopped because of a negative IME report. Since under my new system IMEs will become more impartial and fair there is no need to play this game. Patients who need care will get it and patients who don’t won’t.
Therefore, all bills should be submitted to the central billing interchange within ten days of the expense being incurred. The insurance companies should also be required to pay the bill within a limited period of time (between ten and thirty days is suggested).
Insurance companies are generally large behemoths with sophisticated finance professionals working for them. They can squeeze enormous amounts of profits from any single dollar by investing it a million ways for just days and even hours. This is what insurance companies do! It is unfair for them to be playing this game with money that is owed to health care providers. Often these providers are sole proprietors who worry greatly about making next months rent or voluntary hospitals who are also strapped fro cash flow. They need every cent as soon as possible to keep their doors open and to provide for their communities. The insurance companies will make more money by the reduced fraud then they can by squeezing the providers. Improved cash flow will also help attract more and better providers to the market place.
Insurance Medical Examinations
Insurance medical examinations are the part of the system that is most feared by patients honest health care providers. Anecdotal evidence suggests that the IME process is very slanted in favor of the insurance companies and against the victim patients. I heard a story of a chiropractor who was performing IMEs. The service company, hired by the insurance company to schedule and coordinate IMEs, fired him because he found that over 50% of the patients he examined needed further chiropractic care. Anecdotal evidence suggests that this is a common fear amongst IME providers. Therefore the IME providers tend to find that patients do not need further care. Some providers, I have told me, that they clear 10% or fewer patients for further care. If all the IMEs were being done without bias we should find very similar rates of continuance and denial of care reports across all providers.
IME appointments and reports.
Of particular consternation to me is the appointment for the IME. The insurance company would send me a letter that I should expect contact form their IME service company about an appointment with their doctor. About two weeks later I would receive a letter stating that I had to be at a certain doctor’s office at a certain date and time. Often the location and or time were very inconvenient. I was receiving many therapies multiple times a week and still trying to maintain as close to normal working schedule. Because of the way the system works I was not permitted to call the IME provider directly to change the appointment. I had to call the service company who would call the provider. We often went in circles for a week until I could get an appointment that fit into my schedule. Sometimes the service company would tell me that they needed permission from the insurance company. This would further complicate my ability to get a convenient appointment.
I would suggest a totally different system that eliminates the service providers and works through the interchange. Any provider that wished to do IMEs would register at the interchange. Any insurance company that wished to have a victim be seen for an IME would go to the interchange and register that patient for an IME. The patient would receive the notice that the insurance company wants an IME performed with a registration number. The patient will have 30 days from the date of the notice to get the IME done. The patient would then go the interchange’s website. There would be an IME area that resembles Zocdoc.comii. Providers would post the exact appointment times that they are available to perform IMEs. The patient can search for registered providers, in a particular specialty, within so many miles from their home, at a convenient time. This feature alone would have saved me hours of phone calls and unnecessary travel.
The patient would be allowed to cancel or modify an appointment up to 24 hours before the scheduled appointment. If a patient cancels too late or is a now-show more than three to five times the case should be referred to the ‘Governing Board’ (see below) for review. If the patient did no have valid reason for cancellations and no shows the Board should decide or if future coverage should be limited or denied. The patient may bring along a translator if the do not speak English or request that one be provided with part of the cost charged to the patient. The patient should also be allowed to bring someone to accompany them to witness the examination. The IME provider will then have 48 hours to post his/her report to the interchange website. The patient will then have then days to provide a response to the IME report. The insurance company will then have up to ten days to render its decision on continuation of coverage. All these reports and decisions will be posted to the interchange website. Posting to the website allows all involved easy access. Of course measures will be taken to insure that there is HIPPA compliance throughout.
My experience with the current system is that the IME providers often dilly-dally with their reports. The insurance company staff tries to get the ‘Denial of Coverage’ letters to the insured timely but how quick they get it out depends on their caseload. When they deny coverage it is retroactive to the date that that the IME provider examined the patient. If the patient has been getting treatments during this period they are now on the hook for the cost themselves. Under the new system the patient/victim should have their costs covered up to the day that they receive the denial letter or 48 hours after the company issues a letter.
If a patient still disagrees with the IME providers report or with a company’s denial of serviced then they will have a right to petition before a board. I will discuss this more under the section ‘Governing Board.’
This will be a large and complex system. Therefore managing the new no-fault will also be a large task.
I would start off by recommending a governing board that represents all constituencies. Three members should come from the insurance industry, three should be appointees of the healthcare industry, three should be appointed by the insurance regulators, with at least two of these three being former victims.
One task of the governing board will be to write the regulations. The regulations should, to the extent possible, be fair to the constituencies, especially the victims, with an eye towards minimizing fraud. Non-bureaucratic is an oxymoron whenever government or big business is involved. Never-the-less the board should attempt, in all its endeavors, to make the system open and user-friendly to the victims.
The board should also maintain a ‘consumer services’ function. There should be a staff that is available to receive questions and complaints from victims and help them work out the complaints in a simple and quick fashion. My experience, of long ago, as a New York State Insurance Examiner, in the Consumer Services Bureau, taught me that often those filing complaints simply did not know or understand their rights and responsibilities. They also did not understand how insurance companies worked or insurance industry lingo. A little communication help often went a long way.
Sometimes a complaint is complex. It may be because the case itself is complex. It may be because there is an element of fraud someplace along the way. It may be an element of ‘he said, she said,’ leading to unfulfilled expectations. Any complaint hat cannot be resolved by a staff person should be able to be brought before a hearing board or mediator. This function should be designed so that a victim need not incur the cost of an attorney in order to protect their rights.
Tremendous costs are already being uncured by insurance companies and their policy holders. The costs of this system should be directly paid by the insurance companies into the interchange. The amounts paid in should be correlated with the amount of policies that are written.
The insurance companies have large staffs to manage the claim process (and deny coverage). They also hire outside companies to manage the IME process. If this model works, as I think it will, a lot of the administrative costs will be reduced. Furthermore, I believe that there will be a tremendous reduction in the amount of fraud. Therefore, although there will be initial costs to set-up this system, in the long run, I believe there will be tremendous savings. I estimate the payback period to be less than two years. I think it will be that soon, or sooner, that frauds start to dwindle.
Crime and Punishment
The lynch-pin of this system is the punishment for committing a fraud. Insurance fraud is often seen as a white-collar crime. Since we don’t always see a specific victim with a specific injury, convictions are not always easy and the punishments are not harsh. I view this type of insurance fraud a very, very serious crime. The impact is that the insurance companies over-protect themselves and consequently, innocent, honest, accident victims sometimes don’t the care to which they are rightfully entitled. This crime, therefore, does, cause injury.
Therefore I would suggest very harsh punishment for this convicted of crimes related to insurance fraud. Any convicted fraudster should not only be responsible for economic restitution but also face a long, hard prison sentence. For those who are convicted of these crimes, who are not natural citizens, they should be deported at the end of their prison sentence.
Insurance companies who wrongfully deny care to a victim should face economic penalties. If the ‘victim’ is really a fraudster then they should not get care and face criminal penalties as described above. N However, if the insurance company denies a patient care they should face economic consequences as a fraudster would.
No-fault and workers’ compensation insurance were intended to ease the burden of accident and workplace victims. The Law of Unintended Consequences,’ however, has turned these areas into orchards of ill-gotten fruits for fraudsters. In and effort to combat the fraud the insurance carriers often come down harshly on innocent, honest victims.
This paper presented a method of dealing with no-fault and workers’ compensation claims that will hopefully reduce fraud by tracking accident victims and their health care providers. I believe this system will reduce frauds and therefore reduce costs. The honest victims will receive the care they deserve in an expeditious fashion while the fraudsters will be choked out of the system.
History of no fault insurance. 2012 [cited 8/13 2012]. Available from http://www.nofaultinsuranceguide.com/history-of-no-fault-insurance.
Florida drivers pay A “Fraud tax” that is rising and contributes to higher premiums for honest drivers
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A brief history of insurance department regulation 83: The no-fault fee schedule regulation. 2006 [cited 8/14 2012]. Available from http://www.dfs.ny.gov/insurance/r68/r83_intro.htm.
History of the no-fault concept. 2005 [cited 8/13 2012]. Available from http://www.consumerwatchdog.org/feature/history-no-fault-concept.
Corum, David. 2011.
IRC RELEASE: More than 20 percent of New York City area auto injury claims appear to be fraudulent, says new study of no-fault auto insurance . Malvern, PA: Insurance Information Institute, .
Guyton, Gregory P. 1999. A brief history of workers' compensation. The Iowa Orthopaedic Journal 19 : 106,107-110.
Harger, Lloyd. Workers' compensation, a brief history. 2011 [cited 8/14 2012]. Available from http://www.myfloridacfo.com/WC/history.html.
Lawsky, Benjamin M. 2011. First annual report of the superintendent to the governor and legislature. New York, NY: New York State Department of Financial Services, 1.
i MasterCard and Visa are trademarks of their respective owners.
ii Zocdoc.com is a registered trademark of its owner.
A New Model for No-Fault Insurance 5/22
Associate Professor of Accountancy
Brooklyn College of the City University of New York