IDII providers have been stuck in this loss-making environment for a variety of intertwined and well-known reasons – e.g. by entering into a product features arms race[4], grading of products from rating houses being used in the sales process as a proxy for an assessment of the “best interests” of the policyholder and increasing mental health insurance claims.

So, given that insurers and regulator were already aware of these problems, why hadn’t they made any changes to their products? The main concern appears to be the potential first-mover disadvantages of replacing their current IDII products with a sustainable version. 

• APRA conducted a thematic review of IDII and, in May 2019, issued an industry letter stating that insurers should focus on four areas – strategy and risk governance, pricing and product design, data, and resourcing.

With the industry making over AUD 1 billion in losses from January to September 2019, APRA intervened again in December 2019. In this letter to the industry, APRA imposed an additional capital requirement (delayed to 1 October 2020 due to COVID-19), suggested clear changes to “riskier product features” and set out its expectations for an industry-wide improvement in data.

APRA has just released its “Final individual disability income insurance sustainability measures”[5] on 30 September 2020, which covered three key areas:

• Consequence management: the supervisory adjustment was confirmed to be applied from 1 October 2020; the amount of additional capital for each company was communicated in late 2019. The capital adjustment will be increased or decreased based on APRA’s assessment of each company’s progress in addressing these issues.
• Product features: APRA summarised the feedback received and its final measures

Agreed value: insurers are required to have ceased sales of these products since 31 March 2020.

Income at risk: product benefits must better reflect the claimant’s income at the time of claim.

Replacement ratio: is limited to a maximum of 90% of income at risk for the first 6 months of benefits, and 70% thereafter. Indexation is limited to inflation rates, and there is an allowance for superannuation contributions into a super fund. Recognising the importance of rehabilitation and retraining, these costs are allowed in addition but must be paid directly to the providers (and with regard to regulations).

Contract terms: are limited to 5 years with provisions being made for the policyholder to enter a new contract (based on updated T&Cs) at that time with no medical review but allowing for changes in occupation, financial circumstances and dangerous hobbies.

Benefit term: no limits to benefit terms are imposed but companies must set benchmarks and have effective controls to manage the risks from longer benefit terms.

• Data: finally, APRA re-iterated the importance of timely and detailed data being available for both individual companies to understand their experience and risks, and also for APRA and industry experience studies.

APRA finished this letter by noting that the principles should also be applied to all life insurance products as these issues were not limited to IDII and stated that the “onus is now on individual life companies, and the industry collectively, to move IDII to a sustainable state and thereby deliver better outcomes for policyholders.

On 25 September, the Actuaries Institute released[6] its Disability Income Taskforce’s provisional findings and recommendations[7], a sustainability guide[8] and an IDII reference product[9] for consultation. The Taskforce made 45 recommendations across all aspects of the insurance system – community interests, customers, the market, governance, regulations, financial advice, underwriting, claims management, risk management and the professional responsibilities of all actuaries.

The taskforce’s Reference Product Individual Disability Income Insurance” (for consultation) was designed for stakeholders to use when considering their own IDII products. This is not intended to be a standardised product that insurers should offer; rather it provides a reference against which a company’s specific design and terms and conditions should be considered in terms of management of risk and sustainability of the product terms and pricing.

Finally, the Taskforce also released a framework for measuring and governing the sustainability of insurer’s IDII products (again, for consultation).

We would encourage all interested parties to respond to these consultations to ensure their views are reflected in the final papers.

Currently, life insurers are bleeding from the IDII product and most have started to respond to APRA’s final sustainability measures. The perceived first-mover disadvantage is disappearing and in fact, the last mover disadvantage may emerge for those offering less sustainable products.

The solution is complex and requires life companies to create and price simpler IDII products and devise a strategy to transition inforce business to these new products. It is also clear that insurers will also need to enhance the services they offer (e.g. claims management, wellness initiatives, early intervention, rehabilitation programs etc.), and review all products (not just IDII).

Disability Income Insurance has a valuable product role in meeting consumer needs to protect against key risks. It is clear there is a role for all of us in the insurance industry to drive the changes that are required to continue to be able to offer this, and all life insurance products, sustainably – indeed, with almost 30%[10] of revenue being generated by IDII, the very survival of our industry may be dependent on our efforts.

Stay tuned for Deloitte’s upcoming blog posts and our insights into the life insurance industry.