Question ID: 1054
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Template: S.14.01
Status: Final
Date of submission: 13 Jun 2017
Question
Question 1:
The QRT template S.14.01.01 consists of a life obligation analysis. This is also applied to the Health Insurance as part of the list of SII LoB's (29 - Health insurance). In cells C0190, risk capital amounts is needed, following us this notion is not applicable in our health insurance products: reimbursements of medical expenses. Could you confirm that we can fill these cells with zero or do you have another proposal (i.e. the best estimate of expected out-going cashflows)?
Question2:
In the QRT template S.21.02.01 and s.21.03.01 for Health Insurance of type NSLT, we have to report sum insured by tranches. This notion does not exist for our products. All the medical expenses are reimbursed after the application of a deduction. There is no foreseen limit in the reimbursements from a contract point of view. A notion of PML or EML is proposed in the documentation but we can not reasonnably classify all the portfolio in function of the maximum observed claim for example. Could you advice us on the way of filling in this QRT?
EIOPA answer
In S.14.01 LoB 29 needs to be reported. However LoB 29 is defined as "Health insurance obligations where the underlying business is pursued on a similar technical basis to that of life insurance, other than those included in line of business 33."
Health insurance products with reimbursements of medical expenses should be non-life obligations (LoB 1 - Medical expense insurance) and therefore not reported in S.14.
The classification should be compliant with Art. 55 of Delegated Regulation (EU) 2015/35. The information given may not be fully sufficient to make a judgment about the classification of the specific product in question.
For the LoBs to be reported in S.14 the capital-at-risk is to be calculated in accordance with Article 251 of the Delegated Regulation. The capital-at-risk thus includes the amount that the insurance or reinsurance undertaking would currently pay in the event of the death or disability of the persons insured and the expected present value of amounts that the undertaking would pay in the future in the event of the immediate death or disability of the persons insured under the contract.
In S.21.02 and S.21.03 for the reporting of the 'Sum insured' undertakings should use an estimation of the expected possible loss (calculated using the same methods as used for the calculation of the premium, which should reflect the actual risk exposure).