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OPS-SOP-031 — Reserve Monitoring & Actuarial Trigger Rules

Document IDOPS-SOP-031 Version1.0 Effective Date[TBD — upon adoption] Next ReviewAnnually OwnerFinance / Operations
Prepared ByOperations

1. Purpose & Scope

This SOP establishes reserve monitoring standards and actuarial trigger rules for the Unity Care Member Plan Master Trust. The Trust must maintain adequate liquid reserves to fund claims on a timely basis. This SOP defines the target reserve level, monthly monitoring process, escalation triggers at multiple threshold levels, actuarial review triggers, and the annual reserve adequacy review process.

This SOP applies to: Operations, Finance, Trust administration, and any party responsible for trust funding. Actuarial reporting responsibilities are coordinated through SRS (Stop-loss and Reserve Services) and Davies Actuarial.

2. Definitions

TermDefinition
Trust ReserveThe liquid balance held in the Unity Care Member Plan Master Trust bank account designated for claims funding.
Projected Weekly ClaimsEstimated weekly claims cost = (Allied trailing 3-month average monthly claims) ÷ 4.33 weeks per month.
8-Week Projected ClaimsTarget reserve level = Projected Weekly Claims × 8. Represents approximately two months of claims funding buffer.
PMPMPer Member Per Month — total claims cost divided by total covered member-months. Key actuarial benchmark.
Actuarial TriggerA condition that requires Davies Actuarial to perform a rate or reserve adequacy review.
SRSStop-loss and Reserve Services — coordinates reserve reporting to the reinsurance carrier (HLRA).
Davies ActuarialUnity Care's contracted actuarial firm for reserve adequacy reviews and rate analyses.
Claims Funding SuspensionAn emergency protocol suspending new claims payments when reserves fall below the 2-week threshold, pending emergency funding.

3. Target Reserve Level

Target Reserve: 8 Weeks of Projected Claims Funding

The Trust must maintain a minimum target reserve equal to 8 weeks of projected claims. This provides a buffer against claims volatility, reinsurance recovery lag, and employer premium collection delays.

Calculation: Target Reserve = (Allied Trailing 3-Month Average Monthly Claims × 2)
This formula uses the 3-month trailing average as the projected monthly claims run rate, multiplied by 2 to approximate an 8-week (approximately 2-month) buffer.

The 8-week target is reviewed annually by Davies Actuarial and may be adjusted based on group size, claims volatility, and reinsurance recovery timing.

4. Monthly Reserve Check Process

Operations and Finance perform a monthly reserve check within the first 5 business days of each month. The check compares the actual Trust bank balance against the 8-week projected claims threshold.

Step 1Pull Allied Trailing 3-Month Claims Data
Operations requests the trailing 3-month claims payment summary from Allied Benefit Systems. This report reflects actual claims paid (not incurred) over the prior three calendar months.
Step 2Calculate 8-Week Projected Claims
Finance calculates the 8-week projected claims threshold: (3-month average monthly claims) × 2. This figure is the target reserve floor for the current month.
Step 3Pull Trust Bank Balance
Finance pulls the current Trust bank account balance as of the last business day of the prior month (or current date if available). This is the "actual reserve" figure.
Step 4Compare and Document
Finance documents the comparison in the monthly Reserve Monitoring Log in Acumatica: actual balance, 8-week target, variance (surplus or deficit), and weeks-of-coverage equivalent. Log is reviewed and signed off by Operations Director.
Step 5Apply Trigger Rules
Based on the weeks-of-coverage calculation, apply the trigger rules in Section 5. Escalate immediately if any threshold is breached.
Step 6SRS Reserve Reporting
SRS coordinates monthly reserve reporting to the reinsurance carrier (HLRA) per the reinsurance agreement requirements. Operations provides the reserve summary to SRS within 5 business days of completing the monthly check.

5. Reserve Trigger Rules & Escalation Protocol

Trigger thresholds are non-negotiable floors — not targets. If any threshold is breached, escalation is mandatory and must occur the same business day the deficiency is identified. Do not wait for the next scheduled reporting cycle.
Reserve Level Required Actions Escalation To Timeframe
Below 6 Weeks
(Warning Threshold)
Operations alerts Leadership and Finance immediately. Begin employer premium collection review to identify any past-due premiums. Monitor weekly until reserve returns above 6-week level. Operations → Leadership + Finance Same business day
Below 4 Weeks
(Critical Threshold)
Emergency employer premium collection initiated — all employer groups notified of urgent funding requirement. Davies Actuarial review requested immediately to assess reserve adequacy and recommend corrective action. Weekly reserve checks replace monthly cadence until resolved. Operations → Leadership + Finance + Davies Actuarial Same business day
Below 2 Weeks
(Emergency Threshold)
Claims funding suspension protocol activated. Operations notifies Allied Benefit Systems to hold new claims payments pending emergency funding. Leadership authorizes emergency stop-gap funding action. Davies Actuarial and Legal Counsel notified. Document all actions in writing. Operations → Allied + Leadership + Davies + Legal Counsel Immediately upon identification
Claims Funding Suspension — Important Note: Suspending claims payments may trigger ERISA prompt payment obligations and create participant complaints. Legal Counsel (Dickinson Wright) must be notified any time the 2-week threshold is reached, even if claims are not yet suspended. Legal Counsel advises on participant communication obligations.

6. Actuarial Trigger Rules

In addition to reserve-level triggers, the following actuarial performance triggers require a Davies rate review:

Trigger ConditionRequired ActionOwner
Actual PMPM exceeds 85% of projected PMPM for 2 consecutive monthsDavies rate review required. Operations provides Allied trailing claims data to Davies. Davies evaluates whether current employer premium rates are adequate and whether a rate adjustment or plan design change is warranted.Operations → Davies Actuarial
Single catastrophic claim approaching $350K HLRA attach pointNotify Jason Strain (Brown & Brown / HLRA) immediately. Coordinate reinsurance notification per reinsurance agreement terms. Davies may be engaged for individual claimant projection update.Operations → Jason Strain + Davies
Aggregate claims for any group exceed 110% of projected annual claimsGroup-level actuarial review requested from Davies. Consider rate adjustment at next renewal. Document in group file.Operations → Davies Actuarial

7. Annual Reserve Adequacy Review

Davies Actuarial performs an annual reserve adequacy review of the Unity Care Member Plan Master Trust. The review evaluates:

Operations provides Davies with the full year's claims data (from Allied), enrollment data, and reserve history. The Davies annual reserve report is filed with the Trust records and retained for a minimum of 6 years.

8. Reserve Monitoring Log

Operations maintains a monthly Reserve Monitoring Log in Acumatica. Each monthly entry must document:

FieldDescription
Reporting MonthCalendar month and year for which the reserve check applies
Trust Bank Balance (Actual)Confirmed bank balance as of measurement date
3-Month Trailing Avg Monthly ClaimsAverage monthly claims paid per Allied data
8-Week Projected Claims (Target)Calculated target reserve floor (3-month avg × 2)
Weeks of CoverageActual balance ÷ projected weekly claims
Threshold Breached?None / 6-week warning / 4-week critical / 2-week emergency
Escalation Actions TakenDescription of any escalation steps taken this month
Completed ByOperations/Finance team member and date

9. Roles & Responsibilities

RoleResponsibilities in This SOP
Operations DirectorOwns this process; reviews and signs off monthly reserve log; executes escalation protocol when thresholds are breached
Finance (Acumatica)Pulls Trust bank balance; calculates reserve metrics; documents monthly reserve log entries
Allied Benefit SystemsProvides trailing 3-month claims payment summary; receives claims suspension notifications when 2-week threshold is reached
Davies ActuarialPerforms annual reserve adequacy review; rate reviews triggered by PMPM or reserve triggers
SRSCoordinates reserve reporting to HLRA reinsurance carrier per reinsurance agreement
Jason Strain (Brown & Brown / HLRA)Receives notification of catastrophic claims approaching $350K attach point; reinsurance coordination
Legal Counsel (Dickinson Wright)Advises on participant communication obligations when claims suspension is activated
LeadershipReceives immediate alerts at 6-week and 4-week thresholds; authorizes emergency actions at 2-week threshold