Florida OIR PIP Repeal Impact Final Report

3109 Cornelius Drive
Bloomington, IL 61704
309.807.2300
pinnacleactuaries.com
Roosevelt C. Mosley, Jr. FCAS, MAAA
Principal & Consulting Actuary
rmosley@pinnacleactuaries.com

June 14, 2021

Richard Fox
Budget Director
Florida Office of Insurance Regulation
200 East Gaines Street
Tallahassee, FL 32399

Dear Richard:

Attached is the final actuarial report analyzing the impact of the repeal of Florida No‐Fault.

I, Roosevelt C. Mosley, Jr., FCAS, MAAA, am responsible for the content and conclusions set forth in the
report. I am a Fellow of the Casualty Actuarial Society and a Member of the American Academy of
Actuaries, and am qualified to render the actuarial opinion contained herein.

It has been a pleasure working with you and your team to complete this study. I am available for any
questions or comments you have regarding the report and its conclusions.

Respectfully Submitted,

Roosevelt C. Mosley, Jr. FCAS, MAAA
Principal & Consulting Actuary

Commitment Beyond Numbers

FLORIDA OFFICE OF
INSURANCE REGULATION
The Impact of Repealing
Personal Injury Protection Coverage in Florida

3109 Cornelius Drive
Bloomington, IL 61704
309.807.2300
pinnacleactuaries.com


Contents
PURPOSE AND SCOPE ................................................................................................................................. 2
DISTRIBUTION AND USE .............................................................................................................................. 2
RELIANCES AND LIMITATIONS .................................................................................................................... 2
DATA ........................................................................................................................................................... 3
EXECUTIVE SUMMARY ................................................................................................................................ 5
BACKGROUND ............................................................................................................................................. 7
ANALYSIS OF REPEALING FLORIDA MOTOR VEHICLE NO‐FAULT REQUIREMENTS .............................. 7
ANALYSIS OF REPEAL OF FLORIDA MOTOR VEHICLE NO‐FAULT INSURANCE LAW .................................... 9
FINDINGS ............................................................................................................................................... 9
ANALYSIS ............................................................................................................................................... 9
IRC GROUND‐UP ANALYSIS ................................................................................................................. 10
IRC FLORIDA PIP DATA – CLAIM EXAMINER’S EVALUATION REGARDING TORT ELIGIBILITY ............. 13
EFFECT OF INTRODUCTION OF NO‐FAULT LAWS ............................................................................... 16
EXPERIENCE OF STATES THAT HAVE REPEALED NO FAULT LAWS ...................................................... 17
CONCLUSION – BI LOSS IMPACT RESULTING FROM THE REPEAL OF NO FAULT ................................ 19
UNINSURED AND UNDERINSURED MOTORISTS COVERAGE .............................................................. 20
MEDICAL PAYMENTS COVERAGE ........................................................................................................ 21
CONCLUSION – OVERALL EFFECT OF NO‐FAULT REPEAL ................................................................... 23
IMPACT OF NO‐FAULT REFORM ON THE HEALTH CARE INDUSTRY ................................................... 26
Multi‐Car Accidents ........................................................................................................................... 26
Single Car Accidents .......................................................................................................................... 27
Pedestrians ........................................................................................................................................ 28
Uninsured Drivers ............................................................................................................................. 28
Health Care Insurance ....................................................................................................................... 28
Estimate of Health Care Cost Transfer Using IRC Florida PIP Data #2 – IRC PIP Payments –
Percentage of Fault ........................................................................................................................... 31
Conclusion ......................................................................................................................................... 36
BY COUNTY IMPACTS .......................................................................................................................... 38
RATE EXAMPLES .................................................................................................................................. 39
APPENDICES .............................................................................................................................................. 40
THE IMPACT OF REPEALING
PERSONAL INJURY PROTECTION COVERAGE IN FLORIDA
PURPOSE AND SCOPE
Pinnacle Actuarial Resources, Inc. (Pinnacle) was retained by the Florida Office of Insurance Regulation
(OIR) to conduct an independent actuarial study to estimate the premium impacts of reforms to the
Florida Motor Vehicle No‐Fault laws. The reforms studied were passed in Florida Senate Bill 54 (SB 54)
in the 2021 legislative session, which introduced a series of automobile insurance reforms. Specifically,
SB 54 will repeal Personal Injury Protection (PIP) coverage requirements, require Bodily Injury Liability
(BI) minimum coverage limits of $25,000 per person and $50,000 per occurrence, and require insurers
to offer Medical Payments (MP) coverage. The default MP coverage limits are $10,000, but the
policyholder can either opt out of MP coverage or opt for lower limits.

The proposed effective date of SB 54 is January 1, 2022.

DISTRIBUTION AND USE
This report is being provided to the OIR for its use and the use of makers of public policy in evaluating
the premium impacts resulting from the repeal of Florida Motor Vehicle No‐Fault laws. Specifically, the
OIR may submit this report to the Governor, the President of the Senate and the Speaker of the House
of Representatives. Permission is hereby granted for this distribution on the condition that the entire
report, including the exhibits, is distributed rather than any excerpt. We are available to answer any
questions that may arise regarding this report.

Any third parties receiving the report should recognize that the furnishing of this report is not a
substitute for their own due diligence and should place no reliance on this report or the data contained
herein that would result in the creation of any duty or liability by Pinnacle to the third party.

We have predicated our conclusions on a number of assumptions as to future conditions and events.
We have documented these assumptions in subsequent sections of the report, and readers of this
report must understand these assumptions in order to place our conclusions in their appropriate
context. In addition, our work is subject to inherent limitations, which we also discuss in this report.
RELIANCES AND LIMITATIONS
Listed in the next section are the data sources Pinnacle has relied on in our analysis. We have relied on
the accuracy of these data sources in our calculations. If it were subsequently discovered that the
Florida Office of Insurance Regulation Page 3
Impact of Repealing Personal Injury Protection Coverage in Florida June 14, 2021

underlying data or information is erroneous, then our calculations would need to be revised
accordingly.

We have also relied on a number of assumptions, including assumptions about the implementation of
various provisions of SB 54 and the repeal of certain aspects of the insurance requirements. We
describe these assumptions in detail as part of this report.

We have relied on a significant amount of publicly available data and information without audit or
verification. However, we did review as many elements of the data and information as practical for
reasonableness and consistency with our knowledge of the insurance industry. It is possible that the
historical data used to develop our estimates may not be predictive of future loss and loss adjustment
expense (LAE) experience in Florida. We have not anticipated any extraordinary changes to the legal,
social or economic environment which might affect the number or cost of automobile insurance claims
beyond those contemplated in SB 54 and the OIR statement of work.

Pinnacle is not qualified to provide formal legal interpretation of state legislation or proposed changes
to state legislation. The elements of this report that require legal interpretation should be recognized
as reasonable interpretations of the available statutes, regulations and administrative rules.

DATA
In our analysis, we have relied on data from the following sources:

1. Insurance Research Council (IRC). “2014 Auto Injury Insurance Claims: Countrywide Patterns in
Treatment, Cost and Compensation”
2. National Association of Insurance Commissioners (NAIC), Insurance Services Offices (ISO),
Independent Statistical Services (ISS), National Insurance Statistical Services (NISS) Fast Track
Private Passenger Auto Loss Data – 2nd Quarter, 2020
3. NAIC ISO, ISS, NISS Fast Track Private Passenger Auto Loss Data – 1st Quarter, 2006
4. Earned premium and earned exposure by ZIP Code, 2018 and 2019. ISS, NISS, ISO.
5. A.M. Best annual statement data, 2004 – 2019
6. ISS. “2019 Compilation of Automobile Experience, All Coverages, Florida”
7. IRC. “Uninsured Motorists – 2014 Edition” August 2014
8. Kaiser Family Foundation. “Health Insurance Coverage of the Total Population” 2019
9. The Henry J. Kaiser Family Foundation. “Employer Health Benefits – 2020 Annual Survey”
10. Center For Medicare and Medicaid Services, Office of the Actuary, National Health Statistics
Group. “National Health Expenditures by Type of Sponsor”
11. IRC. “Uninsured Motorists, 2021 Edition”. March, 2021
Pinnacle Actuarial Resources, Inc.

12. NAIC Auto Insurance Database Report 2017/2018
13. American Hospital Association. “Uncompensated Hospital Care Cost Fact Sheet”. 2020


EXECUTIVE SUMMARY
Pinnacle completed an analysis of the impact of repealing the requirement to purchase PIP coverage
and replacing it with a traditional tort liability system. Pinnacle estimated the impact of the repeal on
automobile insurance premiums and the Florida Health Care system. We have determined which
current PIP insurance costs will be covered by other insurance coverages, which costs will be covered
by the health care systems, and which costs will go unreimbursed.

If no‐fault insurance is repealed in Florida, we estimate an overall increase in premiums of 13.3% for all
coverages combined, or $202 per car annually for the average vehicle. This assumes that the current
PIP coverage will be eliminated with the repeal of no‐fault and replaced with medical payments with a
default limit of $10,000. Drivers rejecting first party MP coverage will see an increase of 1.5%, or $23
per car annually on the premium for all coverages combined. For drivers rejecting $10,000 MP
coverage and electing to buy MP coverage with a $5,000 limit, the all coverage premium would
increase by 8.6%, or approximately $131.

For the liability coverage package, the estimated premium increase is 19.6% with $10,000 of MP
coverage. For insureds that reject MP coverage, the estimated premium increase is 2.2%. For insureds
rejecting $10,000 MP coverage and electing to buy MP coverage with a $5,000 limit, the estimated
premium increase is 12.7%.

Given the increase in BI minimum financial responsibility limits from $10,000 per person and $20,000
per occurrence to $25,000 per person and $50,000 per occurrence, the impact on policyholders with
minimum required coverage ($10,000 PIP and $10,000 PD) will be significant. Table 1 summarizes the
overall average impact of the change in coverage for policyholders that carry full coverage and the
impact of the change on policyholders who currently purchase the minimum required coverage. For
policyholders that opt for minimum BI limits and no MP coverage, the estimated increase in premium
will be 48.3%. For policyholders with minimum BI limits and $10,000 MP coverage, the increase in
premium will be 77.2%.


Table 1: Estimated Insurance Reform Impacts
Financial Medical
Coverage Liability Percent All Coverage
Responsibility Payments
Package Change Percent Change
Limit Limit
Full Coverage 25/50 None 2.2% 1.5%
Full Coverage 25/50 $5,000 12.7% 8.6%
Full Coverage 25/50 $10,000 19.6% 13.3%
Minimum 25/50 None 48.3% 48.3%

Minimum 25/50 $5,000 65.8% 65.8%
Minimum 25/50 $10,000 77.2% 77.2%
Full Coverage includes BI, PD, PIP or MP, Comprehensive, Collision, Uninsured
and Underinsured Motorists coverages. Minimum required coverages are
$10,000 PIP and $10,000 PD.

The projection of how current PIP medical losses will be covered if no‐fault is repealed is shown in
Table 2.

Table 2: Impact of No Fault Repeal on Health Care System
Percent Of Current PIP
Current PIP Loss Covered By: Amount
Medical Losses
BI $1,312,020,172
UM $279,328,214
MPC ‐ Not At Fault $115,856,092
MPC ‐ At Fault $664,432,743
Auto Insurance System Subtotal $2,371,637,221 86.7%
Health Care Providers $13,067,694 0.5%
Health Care Insurance $304,433,719 11.1%
Injured Claimant $45,490,096 1.7%
Additional detail on the premium impact is included in the report, including premium examples based
on a mix of demographic characteristics and by county.


BACKGROUND
Analysis of Repealing Florida Motor Vehicle No‐Fault Requirements
Under the current Florida Motor Vehicle No‐Fault law, when a person is injured in or by an insured
vehicle, the injured person first recovers compensation under PIP coverage regardless of who was at‐
fault for the accident. PIP is mandatory in Florida, and PIP coverage consists of:

 A minimum coverage amount of $10,000 per person
 Coverage of 80% of medical expenses
 Coverage of 60% of lost income
 Coverage for replacement services
 Up to $5,000 in death benefits

Florida Motor Vehicle No‐Fault law provides a coinsurance requirement for PIP claimants such that the
claimant is responsible for 20% of medical expense and 40% of lost income.

Claimants may pursue a tort recovery for unrecovered economic damages within the first $10,000 of
PIP losses (coinsurance) and for loss amounts greater than $10,000. Florida Motor Vehicle No‐Fault law
utilizes a verbal threshold for private passenger automobile insurance claims. Claimants cannot recover
non‐economic losses (“pain and suffering”) unless the accident results in:

 Significant and permanent loss of an important bodily function
 Permanent injury within a reasonable degree of medical probability, other than scarring or
disfigurement
 Significant and permanent scarring or disfigurement
 Death

SB 54 was introduced in the Florida Senate in the 2021 legislative session. The provisions of SB 54
include the repeal of no‐fault insurance and the introduction of mandatory BI coverage with limits of
$25,000 per claimant and $50,000 per occurrence. Pinnacle has been asked to provide an estimate of
the impact of this repeal on policyholder premiums.

In addition, Pinnacle has been asked to provide an estimate of the impact for each BI coverage scenario
including MP coverage with and without coverage for emergency medical conditions at limits of $5,000
and $10,000.

Pinnacle has also been asked to provide estimates of the impact on the following:

 Health insurance costs
 Health care costs that would not be covered by insurance and paid by the injured claimant
 Health care costs that would not be covered by insurance and paid by healthcare providers,
including hospitals.


ANALYSIS OF REPEAL OF FLORIDA MOTOR VEHICLE NO‐FAULT INSURANCE
LAW
Findings
If no‐fault insurance is repealed, for all coverages combined, the estimated premium increase is 13.3%,
or approximately $202 per vehicle annually, for insureds electing MP coverage with a $10,000 limit.
The estimated premium increase is 1.5% for policyholders rejecting MP coverage, or $23 per private
passenger automobile annually for the average vehicle. For insureds that reject $10,000 MP coverage
and select MP coverage with a $5,000 limit, the estimated premium increase is 8.6%, or $131 per
vehicle insured annually.

We estimate the liability premium would increase by 19.6% for policyholders who purchase MP
coverage with a $10,000 limit. The estimated liability premium increase is 2.2% for policyholders
rejecting MP coverage. Policyholders rejecting $10,000 MP coverage and electing to replace no‐fault
coverage with first party MP coverage with a $5,000 limit will see an estimated increase in liability
premium of 12.7%.

These estimated effects are the result of our analysis of the 2014 IRC Closed Claim Study automobile
accident injuries data, analysis of the introduction and repeal of no‐fault laws in other states, and claim
frequency and severity data from the Fast Track Monitoring System.

Analysis
Pinnacle was engaged by OIR to evaluate the impact on insurance costs of repealing the current no‐
fault law in Florida. We evaluated this impact using several methods.

1. IRC Ground Up Analysis
Pinnacle completed a ground up claim analysis of the PIP claims in the IRC database to estimate
the impact of the no‐fault repeal on other auto insurance coverages and on the health care
system.

2. IRC Florida PIP Data – Claim Examiner’s Evaluation Regarding Tort Eligibility
This method uses the 2014 IRC closed claim PIP loss data to estimate the impact on BI pure
premium. We also analyzed the Florida IRC data in comparison to other no‐fault states to assess
the relative success of the Florida law in achieving reductions in BI costs.


3. Effect of Introduction of No‐Fault Laws
Pinnacle conducted a review of the effect of the introduction of no‐fault laws on BI losses.

4. Experience of States That Have Repealed No‐Fault Laws
Pinnacle evaluated the experience for states that have repealed no‐fault laws.

IRC Ground‐Up Analysis
The initial estimate of the impact of the repeal of no‐fault was developed using a ground‐up analysis of
IRC PIP claims to determine the disposition of the current PIP claims under the proposed tort system.
The following assumptions were made regarding the coverage applicable to existing Florida PIP claims
if PIP is repealed.

1. For claims that currently meet the tort threshold in the no‐fault system, the current recovery
is:

Current BI Paid Loss + Current PIP Paid Loss

If PIP is repealed, the estimated new losses would all be paid under liability and would be:

Current BI Paid Loss + (Current PIP Economic Loss * Adjustment for Ratio of BI Paid Loss to BI
Economic Loss) – all paid under BI coverage
2. For claims that do not meet the current tort threshold, but would be eligible for tort recovery
if no‐fault was repealed, the current recovery is:

Current PIP Paid Loss + Current BI Paid Loss (for Medical Costs in Excess of Limit)

If PIP is repealed, the new loss would be:

(Current PIP Paid Loss adjusted to remove the impact of fee schedule savings + Current BI Loss)
* Adjustment for Pain and Suffering – all paid under BI coverage
3. For claims that do not meet the current tort threshold, and would not be eligible for tort
recovery if no‐fault was repealed, the current recovery is:

Current PIP Paid Loss

If PIP is repealed, the new loss would be:

Current PIP Economic Loss subject to MP Limit, paid under MP Coverage

Under these assumptions, the calculation of the impact of the repeal of no‐fault is shown in Table 3.

Table 3: Ground Up Analysis of IRC PIP Claims
Current Losses
(1) Current PIP Paid Losses 4,634,365
(2) Current BI Losses 7,275,953
(3) Total Current Losses 11,910,318
Additional BI Losses
PIP Paid Losses for Claims that Currently Meet Verbal Threshold, Adjusted to
(4)
Remove Fee Schedule Savings 2,049,114
Total Economic Loss For Claims That do not Qualify for Tort Recovery Currently,
(5) 1,732,547
but will Qualify for Tort Recovery if No‐Fault is Repealed
(6) Estimated Non‐Economic Loss For Claims That do not Qualify for Tort Recovery 172,750

Currently, but will Qualify for Tort Recovery if No‐Fault is Repealed
(7) Total Additional BI Losses 3,954,412
New Medical Payments Losses
PIP Medical Loss For Claims That do not Qualify Today, Will Not Qualify When
3,906,562
(8) Repealed
1,061,656
(9) Repealed, Subject to $5,000 Limit
1,761,010
(10) Repealed, Subject to $10,000 Limit
Impacts
(11) Impact on BI Losses 54.3%
(12) Impact on BI + PIP Losses ($5,000 Medical Limit) 3.2%
(13) Impact on BI + PIP Losses ($10,000 Medical Limit) 9.1%
(1) 2014 IRC Closed Claim Data, excludes unknown claims from QUALIFYTORT field
(2) (1) * 1.57, Ratio of PIP to BI Losses from Fast Track
(3) (1) + (2)
2014 IRC Closed Claim Data, PIP paid losses where QUALIFYTORT = Yes,
(4)
adjusted to remove fee schedule savings
2014 IRC Closed Claim Data, PIP paid losses where QUALIFYTORT = No,
(5)
QUALIFYWITHOUTTHRESHOLD = Yes
(6) Estimated non‐economic losses based on total losses associated with claim
(7) (4) + (5) + (6)
2014 IRC Closed Claim Data, PIP medical losses where QUALIFYTORT = No,
(8)
QUALIFYWITHOUTTHRESHOLD = No or Blank, Medical Loss
(9) (8) with $5,000 Limit Applied
(10) (9) with $10,000 Limit Applied
(11) (7) / (2)
(12) [ (2) + (7) + (9) ] / (3) ‐ 1.00
(13) [ (2) + (7) + (10) ] / (3) ‐ 1.00

We first estimated the increase in BI losses. The increased losses come from the current PIP paid losses
for PIP claims that qualify for tort recovery and from the PIP paid losses for claims that do not currently
qualify for tort recovery but will qualify after no‐fault is repealed. For this group of new claims, an
adjustment for pain and suffering was added based on the total economic loss associated with the
claim and the ratio of BI payment to economic loss shown in Table 4. This produces additional BI losses
of $3.95 million as shown in line 7 of Table 3.

We expect current PIP claims that do not qualify for tort recovery but would qualify after the repeal of
no‐fault will have an impact on BI losses larger than just the current PIP loss paid. This is because the
amount of BI loss payments also includes a non‐economic loss component and the current PIP
payment is adjusted for coinsurance. The 2014 IRC study indicates that on a countrywide basis, the
ratio of the average BI payment to the BI economic loss decreases in direct proportion to the size of
the economic loss as follows:

Table 4: Ratio of BI Payment to BI Economic Loss
(1) (2) (3) (4) (5)

Economic Loss Number of Average Average Payment per $1.00
Interval Claimants Economic Loss BI Loss Payment of Economic Loss
<500 2,358 249 759 3.05
501‐1,000 1,502 747 1,746 2.34
1,001‐2,000 2,283 1,484 2,984 2.01
2,001‐5,000 4,742 3,365 5,837 1.73
5,001‐10,000 3,406 7,110 10,890 1.53
10,001‐25,000 2,640 15,429 19,602 1.27
25,001‐50,000 801 35,231 40,134 1.14
>50,000 709 178,354 84,877 0.48
Total 18,441 13,051 11,934 0.91
(2) 2014 IRC Closed Claim Study
(3) 2014 IRC Closed Claim Study, Total Economic Loss / (2)
(4) 2014 IRC Closed Claim Study, Total Paid Loss / (2)
(5) (4) / (3)
To estimate non‐economic losses, we apply the ratio above to the economic loss associated with the
claim.

We then estimate the additional MP losses, which are the medical losses associated with PIP claims
that do not qualify for tort recovery today and will not qualify for tort recovery when PIP is repealed.
We estimated losses for both the $5,000 and $10,000 MP limit. The MP estimated losses are $1.06
million and $1.76 million, respectively.

This analysis produces an overall estimated increase in BI losses of 54.3%.
IRC Florida PIP Data – Claim Examiner’s Evaluation Regarding Tort Eligibility
We also develop an estimate based on claim examiner evaluation of tort eligibility. The IRC study
segregates PIP losses based on the claim examiner’s view of the tort eligibility with and without a no‐
fault threshold. The questions asked in the IRC survey are shown below.

1. In your judgment, does this claim qualify for a BI tort recovery under the current no‐fault law
whether or not a tort claim is being pursued?

2. For those claims that did not qualify under the current state threshold, would they be eligible
for recovery if the no‐fault threshold did not exist?

With respect to the first question, the data in the Table 5 indicates that PIP claims that resulted in 49%
of PIP economic losses would be eligible to pursue a tort recovery.

Table 5: Does Claim PIP Claim Qualify for Tort Recovery
(1) (2) (3) (4) (5)

Number Total Economic Average Economic Percent of Total
Response
of Claims Loss Loss Economic Loss
Qualifies 239 $6,850,971 $28,665 49.2%
Doesn't Qualify 427 $5,847,308 $13,694 42.0%
Unknown 112 $1,213,544 $10,835 8.7%
Total 778 $13,911,823 $17,882
(1) 2014 IRC Closed Claim Study ‐ Does claim qualify for BI tort recovery
(4) (3) / (2)
(5) (3) / (3) Total
The IRC survey further asked whether the claims that did not qualify under the current state threshold
would be eligible for recovery if the no‐fault threshold did not exist. As shown Table 6, the claim
examiners indicated that an additional 143 claims, representing approximately $1.9 million of PIP
economic losses, would become eligible for a tort action if the no‐fault threshold did not exist.


Table 6: Would Claim Qualify for Tort if No Fault Threshold Did Not Exist?
Additional Losses Eligible for Tort Action if No‐Fault
Threshold Did Not Exist
Claims Total Loss Average Loss
143 $1,872,010 $13,091

Source: 2014 IRC Closed Claim Study
Therefore, on a pure additional loss basis, this would indicate that the repeal of the threshold would
produce an increase of 27.3% ($1,872,010/$6,850,971) in economic losses from claims that would now
be eligible for BI.

Based on this analysis, we have selected 25% as our estimate of additional BI losses which would be
transferred from PIP based on claims that are currently not eligible for tort recovery but would become
eligible after the repeal of no‐fault. Taking the ratio of BI payment to economic loss from Table 4 for
the average severity of the additional losses ($13,091), the estimated increase including non‐economic
losses is 31.8% (.25 x 1.27).

This is the estimated increase in the BI losses which would result solely due to the additional claims
which would now be eligible for tort recovery given the elimination of no‐fault. However, if the current
no‐fault law were to be repealed, there would also be an additional impact resulting from the fact that
BI awards today are currently reduced by the PIP benefits. As such, it is necessary to quantify this
additional impact.

From the 2014 IRC study, for those Florida BI losses which are subject to the threshold, general
damages (pain and suffering) and special damages (economic loss) represent 69% and 31%,
respectively, of total BI payments as compared to 60% general damages and 40% special damages
countrywide. This implies that approximately 13% of the total loss has been transferred to PIP, as a
13% reduction in special damages losses would produce a 31% ratio of special damages to total losses
[(.40 – x) = .31(1 ‐ x)]. The indicated impact on BI losses would thus be 14.9% (1.00/0.87). Therefore,
the total indicated increase to the BI losses which would result from a repeal of the threshold would be
the combination of the 31.8% increase due to additional claims eligible for tort recovery plus 14.9%
which is attributable to the current PIP claim payments which would now be recoverable under BI. This
produces an overall increase in BI losses of 46.7%.

This is the impact for those losses which are covered by the no‐fault law. The Florida law would not be
applicable to claims involving motorcycles and out of state accidents. Accordingly it is necessary to
adjust the impact to account for the fact that losses not subject to the no‐fault law would be
unaffected by these reforms. Based upon the 2014 IRC Florida data, 93.5% of the BI losses were subject

to a tort threshold under the no‐fault law. Therefore, 6.5% of the BI losses were covered under tort
and would be uninfluenced by the repeal of no‐fault. As such the indicated increase of 46.7% in BI
losses would become 43.7% (.467 x .935).

We additionally examined the IRC Florida BI loss data by size of economic loss in order to validate this
estimate. If the Florida threshold was successful in eliminating the less severe accidents from tort
recovery, we would expect that the Florida distribution of BI loss by size of economic loss would have
fewer claims in the lower economic loss categories than states without a no‐fault threshold. By
comparing this difference in the amount of losses eliminated, it is possible to quantify the savings
achieved by the Florida no‐fault law. The inverse of the savings would produce the cost increase which
would be associated with the repeal of the no‐fault law.

Set forth below is the distribution of BI losses paid above selected dollar intervals of economic loss for
Florida and Countrywide excluding no‐fault states:

Table 7: Distribution of BI Losses Paid
(1) (2) (3) (4) (5)

Florida Countrywide
Economic % of BI % of BI Indicated Indicated
Loss Interval Payments Payments Savings BI Increase
> $5,000 87.8% 74.8% 14.9% 17.5%
> $7,500 84.6% 65.8% 22.2% 28.5%
> $10,000 79.3% 58.5% 26.3% 35.6%
> $12,500 73.4% 53.2% 27.5% 37.9%
> $15,000 66.2% 48.7% 26.5% 36.0%
(1) 2014 IRC Closed Claim Study ‐ BI Economic Losses
2014 IRC Closed Claim Study ‐ Florida BI paid losses for
(2)
specified interval divided by total BI paid losses
2014 IRC Closed Claim Study ‐ Countrywide BI paid
(3) losses for specified interval divided by total BI paid
losses
(4) [(2) ‐ (3)] / (2)
(5) [(2) ‐ (3)] / (3)

As can be seen in Table 7, the percentage of losses above the dollar intervals are appreciably different
for Florida since there are a smaller percentage of lower dollar claims. The indicated savings and
inverse pricing which is implied by this is set forth in columns 4 and 5, respectively. These indicated
increases in BI losses would be directly comparable to the 31.8% increase determined above. This

measures the effect of losses which were eliminated by the threshold, and does not include the
additional effect of the PIP offset to the BI awards.

Effect of Introduction of No‐Fault Laws
It is instructive to review past insurance data in order to determine the impact of the introduction of
prior no‐fault laws on insurance losses. The most readily available data to use for this type of analysis is
the NAIC’s Fast Track experience which first became available in 1975. As Florida’s law initially became
effective in January 1, 1975, it is not possible to review Florida experience before no‐fault. Similarly,
most no‐fault laws became effective prior to 1975 and are therefore unavailable for analysis.

However, North Dakota introduced no‐fault effective January 1, 1976. North Dakota’s no‐fault law has
a threshold of $2,500 in medical losses and 60 days disability. Therefore, we are able to evaluate this
state’s data on a pre and post no‐fault basis. Specifically, we have reviewed claim frequency, claim
severity and loss costs. This data is set forth in Table 8 and Table 9.

Table 8: North Dakota BI Pre‐no‐fault Fast‐Track (Year ending December 1975)
BI Frequency 5.27
BI Severity $2,970
BI Loss Cost $15.66
Table 9: North Dakota Post no‐fault BI Cost and Frequency
Year‐ending Frequency Severity Loss Cost
June 1977 1.89 6,602 12.47
September 1977 1.63 7,676 12.49
December 1977 1.62 7,676 12.47
March 1978 1.58 7,179 11.32
June 1978 1.70 8,016 13.59
Average 1.68 7,430 12.47


The post no‐fault BI pure premiums averaged $12.47 from June 1977 to June 1978. This implies an
actual reduction in BI pure premium of 20.4% (12.47/15.66 = .796). This resulted from a frequency
reduction of 68.1% (1.68/5.27) and a claim cost increase of 150.2% (7,430/2,970).

A reverse cost estimate would imply that if no‐fault were to be repealed at that time, the BI losses
would increase by 1.00/0.796 or 25.6%. With regard to the individual components of loss costs,
frequency would be expected to increase 213%, and severity to decrease by approximately 60%.
However, changes of this magnitude to the individual components would not be expected in Florida
due to the fact that Florida’s BI claim frequency and claim cost are significantly higher than North
Dakota’s.

This estimate of the impact of the repeal of no‐fault on BI costs is based on a $2,500 monetary
threshold, which on an inflation adjusted basis would be approximately $10,000 today. Also, Florida
uses a verbal threshold which cannot be directly compared to the North Dakota threshold.

Experience of States That Have Repealed No Fault Laws
Additionally, we have evaluated the experience for those states which have repealed their no‐fault
laws. The following states have repealed their no‐fault laws since 1991.

Table 10: States That Have Repealed No Fault Laws
State Date of No‐Fault Repeal Dollar Threshold
Nevada 01/01/1980 $750
Georgia 10/01/1991 $500
Connecticut 01/01/1994 $400
Colorado 07/01/2003 $2,500

These states had a dollar threshold lower than the current Florida law provides. As such, the impact
experienced in these states would be expected to be lower than the impact anticipated for Florida, as
fewer BI losses in these states were eliminated due to the weaker thresholds. Nevertheless, it is
instructive to review the post‐repeal data in these states to analyze what actually occurred with the
repeal of no‐fault.

In Georgia, the increase in claim frequency was approximately 26% to 34% higher than the increase in
countrywide claim frequency based on the Fast Track data one year after the repeal of the no‐fault

law. Claim severity decreased approximately 13% to 17%, with a resulting increase in pure premium of
8% to 12%. Given the low threshold in Georgia, it is expected that the change would be significantly
lower than anticipated in Florida.

In Nevada, the claim frequency increased by approximately 57% to 66% with a corresponding
reduction in BI claim cost of 23% to 29%. This resulted in an overall increase in pure premium of
approximately 17% to 24%, with an average increase of 18% over this time interval.

In Connecticut, the claim frequency increased by approximately 20% to 36% with a corresponding
reduction in BI claim cost of between 19% to 26%, resulting in an overall change in pure premium of
approximately ‐3% to +4%. It appears that there were other mitigating factors which impacted
insurance losses in Connecticut during this time, which unfortunately masks the actual effect of the no‐
fault repeal.

As shown in Table 11, Colorado claim frequency increased by approximately 102% to 129% with a
corresponding reduction in BI claim cost of approximately 35%. This resulted in an overall increase in
pure premium of approximately 32% to 51% with an average increase of 45% over this time interval.

Countrywide data for this same time interval shows that BI pure premium trends were generally flat.
Therefore, it is not necessary to adjust these indications for any inflationary or other trends which may
have been applicable at that time.


Table 11: Colorado Fast Track Data
Fast Track Plus
Private Passenger Auto Loss Data and Trends
Colorado
Bodily Injury Percent Changes from 2003‐2
Year Pure Paid Claim Paid Claim Pure Paid Claim Paid Claim

Ending Premium Frequency Cost Premium Frequency Cost
2003 ‐ 1 69.78 0.34 20,510
2003 ‐ 2 70.93 0.35 20,151
2003 ‐ 3 72.18 0.37 19,268
2003 ‐ 4 74.54 0.42 17,871
2004 ‐ 1 76.44 0.49 15,523
2004 ‐ 2 82.02 0.57 14,283
2004 ‐ 3 86.68 0.65 13,397
2004 ‐ 4 93.62 0.71 13,158 32% 103% ‐35%
2005 ‐ 1 100.36 0.76 13,277 41% 117% ‐34%
2005 ‐ 2 104.47 0.78 13,405 47% 123% ‐33%
2005 ‐ 3 105.68 0.8 13,172 49% 129% ‐35%
2005 ‐ 4 106.07 0.81 13,143 50% 131% ‐35%
2006 ‐ 1 107.18 0.81 13,314 51% 131% ‐34%
Conclusion – BI Loss Impact Resulting from the Repeal of No Fault
The estimated increases in BI losses based on the above analyses are summarized in Table 12.

Table 12: Estimated Impact of No‐Fault Repeal on BI Losses
Analysis Estimate
IRC Ground Up Analysis 54.3%
IRC Florida PIP Data 43.7%
Effect of Introduction of No‐Fault Laws – North Dakota 25.0%
Effect of Repeal of No‐Fault Laws – Georgia 8.0% ‐ 12.0%
Effect of Repeal of No‐Fault Laws – Nevada 17.0% ‐ 24.0%
Effect of Repeal of No‐Fault Laws – Connecticut ‐3.0% ‐ 4.0%
Effect of Repeal of No‐Fault Laws – Colorado 32.0% ‐ 51.0%

The following considerations apply to the estimate of the increase in BI losses:

 All states that repealed PIP had dollar thresholds as compared to the verbal threshold which is
in effect in Florida.
 The Colorado experience is particularly applicable here as the Colorado no‐fault law was
repealed most recently, and it had the highest monetary threshold.


Accordingly, we conclude that a repeal of the no‐fault law in Florida can reasonably be expected to
result in an increase in BI claims losses of approximately 32.0% to 54.3%, and we have selected a point
estimate of 45%.

The cost estimates in this report are generally stated in terms of the impact on claim dollars paid on
behalf of the claimant. The impact on claim dollars cannot be used interchangeably with the impact on
premiums. This is because a portion of premium is for general overhead (rent, utilities, etc.) and will
not decrease proportionately to the claim dollars. Based on the 2016 ‐ 2019 A.M. Best’s Aggregates
and Averages, Private Passenger Automobile Liability general and other acquisition expenses represent
12.6% of the industry‐wide auto liability premiums (the ratio of general expenses to earned premiums
plus other acquisition expenses to written premiums). To estimate the premium impacts
corresponding to the cost impacts shown in this report, it is necessary to multiply the cost increase by
a factor of 0.874. Thus a 45% cost increase equates to 39.3% premium increase.

Uninsured and Underinsured Motorists Coverage
For the Uninsured Motorist (UM) and Underinsured Motorist (UIM) coverage, we estimate that the
repeal would result in a similar increase in the UM portion of the UM/UIM coverage losses. Losses that
would be newly covered under the tort system with the repeal of no‐fault will be covered under UM if
the at‐fault party is not insured.

Given the significant increase in premium due to the increased BI financial responsibility, we believe it
is likely that the percentage of uninsured motorists in Florida will increase. Based on the IRC 2019
study of uninsured motorists, Florida has the sixth highest uninsured motorist percentage of 20.4%.
Mississippi has the highest percentage at 29.4%, and Michigan is the next highest as 25.5%. The IRC
estimate is based on the ratio of UM claim frequency to BI claim frequency.

Also, the Auto Insurance Report publishes an annual index of affordability of auto insurance, which
compares the ratio of average auto insurance expenditures to average household income. Based on
2018 numbers, Florida residents have the third highest percentage of expenditures on auto insurance
in the nation, Michigan currently has the second highest percentage. Applying the estimate premium
impact to Florida auto insurance expenditures would move Florida auto insurance expenditures to
second highest in the nation, ahead of Michigan. Therefore, we estimate that the repeal of no‐fault
and the increase in BI financial responsibility limits will result in a 25% increase in the uninsured
motorists population, resulting in a Florida uninsured motorist percentage of 25.5% (20.4% x 1.25).
Adjusting this 25% increase in losses for fixed expenses, we estimate an increase in losses of 21.9%.


We expect there will be no significant change in losses covered under UIM. There could potentially be
a decrease in UIM losses given the mandatory minimum BI limits are higher, however this will be
offset, at least partially, by higher UIM payments due to higher limits of coverage selected.

Based on the 2012 IRC data, the UM losses represent 25% of the total UM/UIM losses, such that the
overall impact on the UM/UIM losses would be an 20.3% increase (((1.45 * 1.25) ‐ 1) * .25). This
equates to an average 17.7% increase in the UM/UIM premium when adjusted for fixed expenses.

The final adjustment for the UM/UIM premium is to account for the increase in limits. Current
policyholders with limits lower than $25,000 per person and $50,000 per occurrence would have their
limits automatically increased to match the new financial responsibility requirement unless they opt
out. The increase in premium is based on the distribution of policies with limits less than
$25,000/$50,000 and distribution of losses that would be paid at each limit. This results in an overall
estimated increase for UM/UIM premiums of 40.3%.

Medical Payments Coverage
Pinnacle was also requested to review the cost impact of MP coverage with limits of $5,000 and
$10,000.

Using the IRC data, we examined PIP payments by size of loss adjusted from an 80% coinsurance basis
to a first dollar of loss basis for Florida and determined that a limit of $5,000 would reduce total PIP
payments by 44% relative to the current limits (See Table 13). We also account for the portion of losses
that are at‐fault (50.1% ‐ see Table 25) and the portion of PIP losses which represent medical payments
(93% ‐ developed from IRC data). We adjust this effect to remove the 80% coinsurance level, which
produces an estimate of the cost of $5,000 medical coverage as a percentage of the current PIP cost of
(.501 * .93 * .56 / .80). For the $10,000 medical coverage limit the estimated percentage of the current
PIP cost is 53% of the current PIP cost (.501 * .93 * .91 / .80).


Table 13: PIP Medical Losses Capped at $2,500, $5,000 and $10,000
(1) (2) (3) (4) (5) (6) (7)

Ratio of Ratio of
Loss Number of Ground Up $5,000 Losses $10,000 Losses
Interval Claims Losses $5,000 $10,000 To Total Losses To Total Losses
(4)/(3) (5)/(3)
0‐2,500 227 $193,923 $193,923 $193,923
2,501‐5,000 118 454,531 454,531 454,531
5,001‐10,000 377 3,362,234 1,885,000 3,362,234
10,001‐15,000 43 521,508 215,000 430,000
15,001‐20,000 5 88,638 25,000 50,000
20,001‐25,000 3 65,442 15,000 30,000
25,001‐50,000 2 69,457 10,000 20,000
50,000+ 4 268,175 20,000 40,000
Total 779 $5,023,908 $2,818,454 $4,580,688 0.56 0.91


Comparable numbers for medical payments excluding emergency services are 17%, 29% and 47% of
the PIP losses for the $2,500, $5,000 and $10,000 medical payments limits, respectively. The exclusion
of emergency medical services results in an estimated 10% reduction in medical payments (see Table
14).

Table 14: PIP Medical Losses Capped at $2,500 and $5,000 and Excluding Emergency Services
(1) (2) (3) (4) (5) (6) (7)

Ratio of Ratio of
Loss Number of Ground Up $5,000 Losses $10,000 Losses
Interval Claims Losses $5,000 $10,000 To Total Losses To Total Losses
(4)/(3) Table 13 (5)/(3) Table 13
0‐2,500 212 $184,819 $184,819 $184,819
2,501‐5,000 111 428,135 428,135 428,135
5,001‐10,000 339 3,015,394 1,695,000 3,015,394
10,001‐15,000 41 491,508 205,000 410,000
15,001‐20,000 3 53,174 15,000 30,000
20,001‐25,000 3 65,442 15,000 30,000
25,001‐50,000 2 69,457 10,000 20,000
50,000+ 2 108,175 10,000 20,000
Total 713 $4,416,104 $2,562,954 $4,138,348 0.51 0.82

We also make an adjustment to the expected MP premium to account for the fact that reforms
implemented with HB 119 will no longer be applicable to MP losses. Based on the 2016 Pinnacle study
estimating the impact of HB 119, Pinnacle estimated that the premium impact of HB 119 was a 15.1%
savings. To adjust for this impact, Pinnacle estimates that the impact on MP premium of the removal of
HB 119 reform provisions will be 17.8% (1.00/.849).


Conclusion – Overall Effect of No‐Fault Repeal
The repeal of the no‐fault law in Florida will result in an increase in BI and UM loss costs. Table 15
shows the increase on a statewide average rate basis would be approximately 2.2% on the liability
coverages, which is approximately $23 per car annually. The increase on a full coverage automobile
insurance package is 1.5%.

Table 15 also illustrates the effect of replacing the current PIP coverage with an optional first party
medical coverage similar to what was offered in Florida prior to enactment of the no‐fault law. This
shows a liability increase of 12.7%, which is approximately $131 per car annually for those electing to
replace PIP coverage with MP coverage that has a $5,000 limit. For MP coverage with a $10,000 limit,
the liability premium increase is 19.6%, which is approximately $202 per car annually.

These estimates do not assume any change in claimant behavior or in the legal environment. There is
the possibility that claimant and attorney behavior will adapt to the new laws. While we are not able to
predict the exact nature of these behavior shifts, we can look to the experience of the Florida market
after the passage of PIP reform associated with House Bill 119 (HB 119) in 2012. Figure 1 shows the
pure premium for PIP coverage in Florida from the fourth quarter of 2010 through the third quarter of
2020. As can be seen from the chart, PIP pure premiums decreased significantly after the passage of
HB 119 in 2012. However, in 2015, PIP pure premiums increased by almost 20%, and have increased
steadily ever since. The last points on the chart represent the impact of the COVID‐19 pandemic on
miles driven. Therefore, there is potential for unexpected changes in behavior that could increase costs
in the future.


Figure 1: Florida Personal Injury Protection Pure Premium
Florida Personal Injury Protection Pure Premium
280.00
260.00
240.00
220.00
Pure Premium
200.00
180.00
160.00
140.00
120.00
100.00
2010 ‐ 4
2011 ‐ 1
2011 ‐ 2
2011 ‐ 3
2011 ‐ 4
2012 ‐ 1
2012 ‐ 2
2012 ‐ 3
2012 ‐ 4
2013 ‐ 1
2013 ‐ 2
2013 ‐ 3
2013 ‐ 4
2014 ‐ 1
2014 ‐ 2
2014 ‐ 3
2014 ‐ 4
2015 ‐ 1
2015 ‐ 2
2015 ‐ 3
2015 ‐ 4
2016 ‐ 1
2016 ‐ 2
2016 ‐ 3
2016 ‐ 4
2017 ‐ 1
2017 ‐ 2
2017 ‐ 3
2017 ‐ 4
2018 ‐ 1
2018 ‐ 2
2018 ‐ 3
2018 ‐ 4
2019 ‐ 1
2019 ‐ 2
2019 ‐ 3
2019 ‐ 4
2020 ‐ 1
2020 ‐ 2
2020 ‐ 3
Year Ending Quarter

Please note that Table 15 is illustrative of the impact for an average policyholder carrying a full
coverage package. Policyholders with higher or lower limits of coverage, different risk characteristics or
who have cars which are more or less expensive than average will see different impacts than
illustrated.


Table 15: Premium Impact of No‐Fault Repeal
Statewide Average Premium Change
Repeal of No Fault
Auto Insurance Current Revised Percent
Coverage Average Rate Average Rate Change
Bodily Injury 369.04 622.70

Personal Injury Protection* 286.97
Uninsured Motorist 139.09 195.12
Property Damage 236.98 236.98
Liability Subtotal 1,032.08 1,054.80 2.2%
Comprehensive 134.01 134.01
Collision 356.23 356.23
Total Major Coverages 1,522.32 1,545.04 1.5%
Repeal of No Fault + $5,000 Med

PIP*/Optional $5,000 Med Pay 286.97 108.16
Collision 356.23 356.23

Collision 356.23 356.23
* PIP average rate includes basic, deductible optional and excess PIP plus residual medical coverages.

Impact of No‐Fault Reform on the Health Care Industry
Pinnacle was asked to estimate the indicated costs that would be transferred to the health care
industry if the Florida Motor Vehicle No‐Fault law is repealed.

Multi‐Car Accidents
For the most common type of accident (a multi‐car accident with one party at‐fault), both the at‐fault
and not‐at‐fault parties currently are able to recover their medical expenses from PIP coverage for the
vehicle they occupied. Under the new tort system, the not‐at‐fault parties would not be able to recover
their medical expenses from PIP since this coverage would be eliminated, but would be able to sue for
all medical and other damages. The at‐fault party’s BI coverage would be responsible for providing
coverage for these costs unless the at‐fault party was uninsured. However, before using the tort
remedy for these expenses, the not‐at‐fault parties could utilize MP, subject to the limits purchased, to
cover their medical expenses, if MP was not rejected. Therefore, not all not‐at‐fault PIP losses will be
transferred to BI, as some of the medical expense will be picked up in whole or in part by MP. These
losses which are covered by MP could ultimately be subrogated into the BI claim by the not‐at‐fault
driver’s insurer.

With respect to the at‐fault party in this type of accident, the driver would not be able to recover
his/her costs from PIP as they would be able to do under the current system. The driver would now be
responsible for these costs. There are several options available to the at‐fault parties for
reimbursement of their losses. The first option would be the situation in which the at‐fault party
purchased MP coverage from their insurance company, as most insureds do in tort states. Based upon
the 2016 NAIC Auto Database (Table 16) for tort states, approximately 66.2% of insureds purchase this
coverage, with limits of $5,000 and $10,000 being the most prevalent. The at‐fault party would be able
to collect from their MP coverage for any medical expense incurred from first dollar of loss. For costs in
excess of their MP limits (or for all costs in the event that they did not purchase MP), the at‐fault party
would have to utilize his/her/their health care insurance, if available, to cover these expenses. Finally,
in the event that the at‐fault party did not have a health care plan, then the medical losses would be
not be reimbursed and the individual would be responsible for these costs. Given that the default
coverage will be $10,000 unless the policyholders rejects coverage or selects a lower limit, we estimate
that the percentage of insureds purchasing MP coverage will be 75%.

Table 16: Ratio of Medical Payments Exposure to Bodily Injury Exposure – Tort States
(1) (2) (3) (4) = (3) / (2)

Medical Bodily
Payments Injury
STATE Exposure Exposure Ratio
Alabama 2,684,144 3,640,257 73.7%
Alaska 322,215 474,199 67.9%
Arizona 1,611,980 4,286,295 37.6%
California 11,084,898 26,549,523 41.8%
Colorado 2,967,066 3,852,582 77.0%
Idaho 895,748 1,079,940 82.9%
Illinois 5,919,904 6,655,048 89.0%
Indiana 4,109,404 4,484,025 91.6%
Iowa 2,276,012 2,351,440 96.8%
Louisiana 1,437,599 2,794,748 51.4%
Maine 984,594 785,773 100.0%
Mississippi 1,412,285 1,806,091 78.2%
Missouri 2,618,920 3,771,510 69.4%
Montana 451,087 736,736 61.2%
Nebraska 1,402,073 1,478,515 94.8%
Nevada 761,855 1,791,601 42.5%
New Hampshire 942,638 859,783 100.0%
New Mexico 781,297 1,381,656 56.5%
North Carolina 5,220,423 7,625,560 68.5%
Ohio 6,798,232 7,602,449 89.4%
Oklahoma 1,194,523 2,466,776 48.4%
Rhode Island 598,431 603,466 99.2%
Tennessee 3,767,017 4,436,166 84.9%
Vermont 358,358 373,739 95.9%
West Virginia 935,186 1,260,406 74.2%
Wyoming 366,356 424,107 86.4%
Total Tort States 61,902,245 93,572,391 66.2%

Source: NAIC Auto Insurance Database Report 2017/2018
Single Car Accidents
For single car accidents, the driver of the vehicle will be presumed to be the at‐fault party in virtually
every situation, and will effectively be in the same predicament as the at‐fault party described above.
For a single car accident involving injuries to the occupants of the vehicle, the guest passenger
occupants of the vehicle would be able to present a claim against the driver of the vehicle for their
injuries and would be in a similar circumstance to the not‐at‐fault parties’ situation described above.
For the occupants of the at‐fault vehicle, family members would be unable to present a claim for
damages in most instances due to the use of intra‐family policy exclusions which are prevalent in
Florida.


Pedestrians
Pedestrians that are injured in an automobile accident would usually be considered as other not‐at‐
fault parties. Pedestrians would be able to present a claim for their injuries as a not‐at‐fault party
unless the driver of the at‐fault vehicle did not have insurance.
Uninsured Drivers
There will be situations where the at‐fault party is uninsured and will not have BI coverage. UM will
provide coverage for the expenses in this situation, subject to the limit which is purchased by the
insured. In addition, the injured party in most cases will have MP coverage, if purchased, as a first
remedy for minor medical expenses, but will need to rely on their UM coverage for those expenses in
excess of their MP coverage. For purposes of this analysis, we have presumed that the percentage of
Florida drivers who purchase UM is 62%, which is based on the 2019 Statistical Agent Data.

Health Care Insurance
Currently, health care insurance provides coverage that is secondary to PIP. With the repeal of no‐
fault, for those instances where the other automobile insurance mechanisms as set forth above are not
applicable, the injured party’s health care insurance would now become primary. According to The
Henry J. Kaiser Foundation1, 86.9% of the population in Florida was covered by health insurance during
2019 as opposed to 90.8% countrywide. For purposes of our analysis we have used 87% as our
estimate of the percentage of Floridians with health insurance.

Estimate of Health Care Cost Transfer Using IRC Florida PIP Data #1 – Claims Examiner’s Evaluation
Regarding Tort Eligibility.

As discussed above in the section on the no‐fault repeal, the IRC study segregates PIP losses into
separate categories based upon the claims examiner’s evaluation.

1
The Henry J. Kaiser Foundation, Health Insurance Coverage of the Total Population, 2019,
https://www.kff.org/other/state‐indicator/total‐
population/?dataView=0&currentTimeframe=0&sortModel=%7B%22colId%22:%22Location%22,%22sort%22:%22asc%22%
7D.


Table 17: Medical Paid Losses Based on Tort Qualification
Average Paid Medical
Response Number of Claims Paid Medical Loss % of Total PIP Loss
Loss
Qualifies 239 $1,967,902 $8,234 43.2%
Doesn't Qualify 427 $2,583,360 $6,050 56.8%
Total 666 $4,634,448 $6,834
As shown in Table 18, the claim examiners also indicated that an additional 143 claims, representing
just under $1.0 million of paid PIP medical losses, would become eligible for a tort action if the no‐fault
threshold did not exist.

Table 18: Additional Medical Paid Losses That Would Qualify for Tort Recovery
Additional PIP Medical Paid Losses Eligible for
Tort Action if No‐Fault Threshold Did Not Exist
Medical Paid Average Medical

Claims Loss Paid Loss
143 $984,223 $6,882

This indicates that the repeal of the threshold would produce an increase of 21.2%
($984,223/$4,634,448) in medical losses which would be tort eligible under a traditional tort system.
Therefore, the total amount of PIP medical payments which would be eligible for a tort recovery if no‐
fault were to be repealed according to the claims examiners estimations would be 64.4% (43.2% +
21.2%).

Based on the A.M. Best Page 14 Data, the total PIP paid losses in Florida in 2019 was $2.940 billion. The
IRC data shows that approximately 93% of the PIP paid losses were for medical coverages. This results
in an industrywide PIP medical loss payment estimate of $2.735 billion. Applying the percentages
derived above to the base PIP medical losses indicates the following:


Table 19: Estimated Losses Not Covered by Auto Insurance – Claim Adjuster Estimate
(1) Total Florida Paid PIP Medical Loss 2,734,628,730 (A.M Best Page 14 PIP Paid Losses, Florida, 2019 ) * .93

(2) Percentage of Drivers Not‐at‐fault 64.40% Estimate based on 2014 IRC Closed Claim Study ‐ Claim Examiner Evaluation
(3) Total PIP Medical Loss Eligible for Tort Recovery 1,761,100,902 (1) * (2)
(4) Percent of At‐fault Drivers not Insured 25.50% IRC, "Uninsured Motorists, 2019 Edition"
(5) PIP Medical Losses Covered by BI Coverage of At‐Fault Driver 1,312,020,172 (3) * 1.0 ‐ (4)
(6) Loss involving uninsured operator 449,080,730 (3) ‐ (5)
(7) Percentage of Policyholders that do not Purchase UM 37.80% Estimate based on ISS, NISS and ISS BI and UM Florida exposure data
(8) PIP Medical Losses Covered by UM Coverage of Claimant 279,328,214 (6) * 1.0 ‐ (7)
(9) Total Remaining Medical Loss after BI & UM 169,752,516 (6) ‐ (8)
(10) Percentage of Policyholders that Purchase MP Coverage 75.00% Estimate based on 2016 NAIC Auto Database
(11) Perentage of PIP Medical Losses Covered Under $10,000 MP Limit 91.00% Estimate from Table 12
(12) PIP Medical Losses Covered by MP 115,856,092 (9) * (10) * (11)
(13) Total Remaining Medical Loss Not Covered 53,896,424 (9) ‐ (12)
(14) Percentage of Drivers At‐fault 35.60% 1.0 ‐ (2)

(15) Total PIP Medical Loss Not Eligible for Tort Recovery 973,527,828 (1) * (15)
(16) Perentage of PIP Medical Losses Covered Under $10,000 MP Limit 664,432,743 (24) * (10) * (11)
(18) Total Not Recovered from auto insurance 362,991,509 (13) + (17)

Of the $2.735 billion in medical PIP losses, 64.4% of the losses ($1.761 billion) would be “not‐at fault,”
thus the primary remedy would be the use of the tort system. However, not all of these losses would
automatically be covered under BI, since some of these accidents may involve drivers without BI
coverage. Of the $1.761 billion, $449.1 million may not be collectible since there is a 25.5% probability
that the loss was caused by a driver without BI coverage. Of this $449.1 million, we have assumed that
62.2% of the insured drivers will purchase the UM coverage, such that $279.3 million of this will be
paid by UM. Of the remaining $169.8 million, the injured party would then be able to utilize their MP
coverage to defray their expenses. Given that 75.0% of the people would have this coverage and 91%
of the losses would be within the limits purchased (assuming a $10,000 MP limit), $115.9 million would
be compensated under MP, leaving $53.9 million as the unrecoverable losses from the auto insurance
system.

For the at‐fault operator, the only remedy from the automobile insurance system would be his/her MP
coverage if it was purchased. Of the $2.735 billion in total medical PIP losses, 35.6% of the total PIP
medical losses would not be eligible for recovery under the tort system (BI or UM coverage) since the
injuries were sustained by the at‐fault operator. Therefore, $973.5 million of the total losses would be
eligible for recovery from MP. MP would cover $664.4 million of these losses, leaving $309.1 million as
not being recoverable from the automobile insurance system for the at‐fault parties. This amount,
together with the unrecoverable amount of $53.9 million from the not‐at‐fault parties, produces a
total of $363.0 million as unrecoverable from the automobile insurance system.

These losses would still be able to be recovered from the health care system to the extent that some
form of health care is available to these individuals. According to the American Hospital Association in
their 2020 publication “Uncompensated Hospital Care Cost Fact Sheet,” 2017 and 2018
uncompensated hospital costs (charity and bad debt write‐offs) averaged 3.56% and 3.68% of all

expenses, respectively. We have assumed an average of these percentages, 3.6%, would carry forward,
and have applied that average to the portion of losses not covered by the auto insurance mechanism.
Thus, $13.1 million of this $363.0 million would be absorbed by health care providers.

Since 87% of Florida residents purchase health care insurance, this would mean that out of the total
$2.735 billion of PIP medical losses, $45.5 million (1.7%) of the total PIP medical losses would not be
covered under some form of insurance and thus covered by the injured claimant. This represents
12.5% of the remaining amount not covered by insurance. The amount that would be covered under
health care insurance is approximately $304.4 million.
Table 20: Costs Recovered Under Health Care System – Claim Adjuster Estimate
Total Not Recovered under Auto Insurance System 362,991,509
Total Covered by Health Care Providers 13,067,694
Covered Under Health Care Insurance 304,433,719
Covered by Injured Claimant 45,490,096

Estimate of Health Care Cost Transfer Using IRC Florida PIP Data #2 – IRC PIP Payments –
Percentage of Fault
As an alternative to the claims examiners’ estimates, we have reviewed the amount of loss which
would be transferred to BI as a percentage of PIP loss for the not‐at‐fault parties using the distribution
of claims by accident type.

Per the 2012 IRC study, the majority of claimants were injured in two‐vehicle accidents (78% of BI
claimants and 68% of PIP claimants). Just 6% of BI claimants were injured in single‐vehicle accidents
and 16% were injured in accidents in which three or more vehicles were involved. Among PIP
claimants, 19% were involved in single‐vehicle accidents, while 13% were in accidents involving three
or more vehicles.

Specifically, in Florida, the distribution of PIP claims and PIP medical losses paid by type of accident
were as follows2:

2
Note – data omissions regarding type of accident accounted for 10.0% of the number of claims and 0.1% of the medical
losses and have been excluded from this analysis.

Table 21: PIP Claims and Medical Losses by Type of Accident
Percent of
Percent of Total Medical
Total Claims Paid
Single Car Accidents 18.6% 18.4%
2 Car Accidents 68.2% 68.1%
3 or more Car Accidents 13.1% 13.5%

We have assigned fault for these types of accidents based upon an assumption that approximately 50%
of the drivers would be considered at‐fault for a two‐car accident, 33.3% for a three‐car accident, etc.
For our fault estimate, we have relied on the Florida PIP IRC distribution of drivers and occupants by
type of accident, and assigned the probability of fault such that the driver of the not‐at‐fault vehicle(s)
and all occupants of all vehicles would be considered not‐at‐fault, and the driver of the at‐fault vehicle
would be considered as at‐fault3. The distribution of claims involving drivers, occupants or pedestrians
for each level of cars involved in the accident is shown in Table 22.

Table 22: Percent of Total Medical Loss
Claims Involving
Cars Involved in
Driver Occupant Pedestrian
Accident
1 43.8% 25.3% 30.9%
2 86.9% 10.0% 3.1%
3 or more 90.9% 9.1% 0.0%

The occupants of the not‐at‐fault vehicle and pedestrians would be able to recover from the at‐fault
party under a tort system. Additionally, the non‐family occupants of the at‐fault vehicle would also be
able to recover for their injuries from the tort system, but family occupants of the at‐fault vehicle
would not be able to pursue tort claims due to the utilization of intra‐family limitations on lawsuits. We
have further assigned a fault probability to the distribution of accidents such that only the driver of the
at‐fault vehicle is considered at‐fault.

3
We have excluded those claims for which detail was not provided for either the by ”type of accident” or “role of claimant,”
which represents 10.4% of the overall data.

The 2014 IRC Auto Study contained data that provided details concerning the relationship of the
occupants to the named insured. The Florida PIP medical loss data indicates that for passengers in the
vehicle, 88% of the medical loss was paid to the named insured or someone related to the named
insured, with 12% of the loss paid to other persons.

Table 23: Losses Paid by Claimant Type
(1) (2) (3) (4) = (3) / (2) (5) = (3) / (3) Total
Average
Number Total Medical Percent of
Claimant Medical Loss
of Claims Loss Paid Medical Loss Paid
Paid
Insured 481 3,391,990 7,052 67.5%
Family Member 170 1,017,906 5,988 20.3%
Other/Unknown 127 612,588 4,824 12.2%
Total 778 5,022,484

Therefore, we have assumed that 87.8% of the occupants in an accident would be related to the driver.

Accordingly, we have applied the following percentages of fault to the percentage of medical loss by
type of accidents in the following manner:
 Single‐car accidents
o 100% fault to the driver of the vehicle
o Occupants
 88% fault to the occupants since they would be related to the operator of the car
 12% not‐at‐fault since these occupants would be unrelated to the driver and be
eligible to file a tort claim
o Pedestrians: 100% not‐at‐fault

 Two‐Car Accidents
o 50% of the drivers as at‐fault and 50% as not‐at‐fault
o At‐fault vehicle occupants
 Assigned fault to 88% of the occupants since they would be related to the
operator of the car

 12% not‐at‐fault since these occupants would be unrelated to the driver and be
eligible to file a tort claim
o All occupants of the not‐at‐fault vehicle were considered not‐at fault

 Three or More Car Accidents
o Assumed that one‐third of the vehicles were at‐fault and two‐thirds not‐at‐fault
o Assigned the probability of fault to the drivers and occupants in the same manner as for
the two‐car scenario as set forth above after using the one‐third and two‐thirds
assignment of fault
Applying these “fault” percentages to the percentage of PIP medical losses produces the following
results.

Table 24: Fault Estimates
Distribution of Total Medical Loss by Number of Cars in Accident
Cars Involved Claims Involving
in Accident Driver Occupant Pedestrian
1 43.8% 25.3% 30.9%
2 86.9% 10.0% 3.1%
3 or more 90.9% 9.1% 0.0%
(1) ‐ 2014 IRC Closed Claim Study
At Fault Assignment by Number of Vehicles in Accident
1 100.0% 100.0% 0.0%
2 50.0% 50.0% 0.0%
3 or more 33.3% 33.3% 0.0%
(2) ‐ Assumes each vehicle equally likely of being at fault
At Fault Assignment for Drivers and Occupants
1 100.0% 88.0% 0.0%
2 100.0% 88.0% 0.0%
3 or more 100.0% 88.0% 0.0%
(3) ‐ Pinnacle estimate, at fault driver 100% at fault, 88% of occupants at fault
At Fault Assignment
1 43.8% 22.3% 0.0%
2 43.4% 4.4% 0.0%
3 or more 30.3% 2.7% 0.0%
(4) = (1) * (2) * (3)
Cars Involved (5) (6) (7) (8)

in Accident Total Medical Loss Dist At Fault Not At Fault
1 66.1% 21.3% 14.1% 7.2%
2 47.8% 67.7% 32.4% 35.3%
3 or more 32.9% 11.0% 3.6% 7.4%
Total 50.1% 49.9%
(5) = Sum(4) by number of cars involved in accident
(6) ‐ 2014 IRC Closed Claim Study
(7) = (5) * (6)
(8) = (6) ‐ (7)
Based on these fault estimates, the impact on health insurance is developed in Table 25.


Table 25: Estimated Losses Not Covered by Auto Insurance – Percentage of Fault Estimate
(1) Total Florida Paid PIP Medical Loss 2,734,628,730 (A.M Best Page 14 PIP Paid Losses, Florida, 2019 ) * .93

(2) Percentage of Drivers Not‐at‐fault 49.90% Estimate based on 2014 IRC Closed Claim Study ‐ Claim Examiner Evaluation
(3) Total PIP Medical Loss Eligible for Tort Recovery 1,364,579,736 (1) * (2)
(4) Percent of At‐fault Drivers not Insured 25.50% IRC, "Uninsured Motorists, 2019 Edition"
(5) PIP Medical Losses Covered by BI Coverage of At‐Fault Driver 1,016,611,904 (3) * 1.0 ‐ (4)
(6) Loss involving uninsured operator 347,967,833 (3) ‐ (5)
(7) Percentage of Policyholders that do not Purchase UM 37.80% Estimate based on ISS, NISS and ISS BI and UM Florida exposure data
(8) PIP Medical Losses Covered by UM Coverage of Claimant 216,435,992 (6) * 1.0 ‐ (7)
(9) Total Remaining Medical Loss after BI & UM 131,531,841 (6) ‐ (8)
(10) Percentage of Policyholders that Purchase MP Coverage 75.00% Estimate based on 2016 NAIC Auto Database
(11) Perentage of PIP Medical Losses Covered Under $5,000 MP Limit 91.00% Estimate from Table 12
(12) PIP Medical Losses Covered by MP 89,770,481 (9) * (10) * (11)
(14) Percentage of Drivers At‐fault 50.10% 1.0 ‐ (2)

(15) Total PIP Medical Loss Not Eligible for Tort Recovery 1,370,048,994 (1) * (15)
(16) Perentage of PIP Medical Losses Covered Under $5,000 MP Limit 935,058,438 (24) * (10) * (11)
(18) Total Not Recovered from auto insurance 476,751,915 (13) + (17)
Table 26: Costs Not Covered Under Health Care System – Percentage of Fault Estimate
Total Not Recovered under Auto Insurance System 476,751,915
Total Covered by Health Care Providers 17,163,069
Covered Under Health Care Insurance 399,842,296
Covered by Injured Claimant 59,746,550
Thus, the estimate of the amount of PIP losses which would not be covered by other forms of
insurance would be $59.7 million using this method versus the $45.5 million using the claims
examiner’s evaluation. This amounts to a difference of 0.5% of the total PIP losses.

Conclusion
The estimate of the losses to be covered by health care predicated on the claim examiner’s evaluation
is shown below.
Table 27: Final Estimate of Transfer of Costs to Health Care Based on Claim Examiners Estimate
Medical Losses
BI $1,312,020,172
UM $279,328,214
MPC ‐ At Fault $664,432,743

Based upon the claims examiner’s evaluation estimate, roughly $45.5 million of the total PIP medical
losses of $2.735 billion will not be covered by any type of insurance system. This represents 1.7% of
the total PIP medical losses. The automobile insurance system will continue to cover the majority of
these losses with approximately 86.7% of the prior losses remaining within this system. 11.1% of the
previous PIP medical losses will be transferred into the health care insurance system, and 0.5% of the
PIP medical losses will be covered by health care providers.

Table 28: Final Estimate of Transfer of Costs to Health Care Based on At‐Fault Estimate
Medical Losses
BI $1,016,611,904
UM $216,435,992
MPC ‐ At Fault $935,058,438

Based on the at‐fault estimate, roughly $59.7 million out of the total PIP medical losses of $2.735
billion will not be covered by any type of insurance system. This represents 2.2% of the total PIP
medical losses. The automobile insurance system will continue to cover the majority of these losses
with approximately 82.6% of the prior losses remaining within this system. 14.6% of the previous PIP
medical losses will be transferred into the health care insurance system, and 0.6% of the PIP medical
losses will be covered by health care providers.

The 2019 Florida PIP average premium based on industry data was $286.974. This average rate covers
both the medical and other PIP losses. Medical loss payments represent 93% of the total PIP losses.
Therefore the average medical portion of the PIP average rate would be $266.88 (.93 x 286.97). Based
upon the claim examiners’ analysis, 11.1% of the current PIP medical loss payments would be
transferred to the health care insurance system. This would represent $29.62 of the average rate (.111
x $266.88). Therefore, all other things assumed being equal, it could be expected that average annual
health care insurance premiums would need to be increased by this amount per car in order to cover
the additional losses which will now be transferred to the health care system.

4
Includes basic, deductible optional and excess PIP coverages.

Based upon the at‐fault analysis, 14.6% of the current PIP medical loss payments would be transferred
to the health care insurance system. This would represent $38.96 of the average rate (.146 x $266.88).

The overall average health insurance premium for 2020 in the South region based on the annual Kaiser
Survey of Employer‐Sponsored Health Benefits5 was $7,296 for a single participant and $20,593 for a
family. The average amount of $29.62 – $38.96 which would be transferred to the health care
insurance system is on a per vehicle basis. This could represent either a single driver or family, and is,
therefore, not directly comparable to the average health care insurance premiums which are on a
single participant versus family basis.

We have related the per vehicle average medical PIP premium which would be transferred to the
health care insurance system to both the single participant and family average health care premiums
as shown below:
Table 29: Impact on Health Insurance Premiums
PIP Medical PIP Medical Percent

Heath Care Assumed % Impact:
Health Amount Amount Impact:
Insurance Number of Low
Care Plan Transferred: Transferred: High
Premium Cars Estimate
Low Estimate High Estimate Estimate
Single $7,296 1 car $29.62 0.4% $38.96 0.5%

$20,593 1 car $29.62 0.1% $38.96 0.2%
Family $20,593 2 cars $59.24 0.3% $77.92 0.4%
$20,593 3 cars $88.86 0.4% $116.88 0.6%
The impact to the average health care insurance premiums due to the shift of PIP losses into the health
care insurance system is estimated to be between 0.1% and 0.4% based on the claim examiners’
evaluation. The impact based on the at‐fault method is 0.2% to 0.6%.

By County Impacts
Applying the estimated impacts of the PIP repeal shown above to average premiums by county
produces estimated premium impacts as shown in Appendix 1.

Financial Responsibility Limit Options

5
The Henry J. Kaiser Family Foundation. “Employer Health Benefits – 2020 Annual Survey”.

To estimate this impact of the increase in the financial responsibility limits, we applied the
$10,000/$20,000, $15,000/$30,000 and $25,000/$50,000 limits to the BI claims in the IRC data. The
percentage of the incurred losses paid at each limit is shown below.

Table 30: Percentage of Claims Covered at Each FR Limit
Financial Responsibility Limit Percentage of Losses Covered
$10,000/$20,000 44%
$15,000/$30,000 59%
$25,000/$50,000 76%
We, therefore, estimate that policies currently with a $10,000/$20,000 limit, the overall impact on BI
losses will be an increase of 20.7% ([.76/.44 ‐1.00] * .285), which is the estimated increase in additional
losses covered adjusted for the percentage of policies that purchase minimum BI limits. The estimate
of policies that purchase $10,000/$20,000 BI limits is 28.5%, which is based on Statistical Agent
exposure data. For the $15,000/$30,000 limit, the additional increase in BI losses would be 0.4%
([.76/.59 ‐1.00] * .014), as only 1.4% of policyholders currently select limits of $15,000/$30,000.

Pinnacle has also estimated the impact on current policies that carry only the required minimum
coverages ($10,000 PIP and $10,000 PD). This is shown in Appendix 2.

Rate Examples
The OIR requested that impacts on different risk scenarios be provided for the impacts of the PIP
repeal. To accomplish this, Pinnacle used the auto rate examples provided by the OIR on their website.

The OIR includes rate examples by county for three risk examples: a single female, a senior operator
and a family risk. The specifications of these rate examples are shown in Appendix 3, Page 7.

Premiums provided on the OIR website are all coverage premiums. Pinnacle calculated the average
premium by county for each of the scenarios across all the insurance companies. We then split the all
coverage premium into by coverage components using the average premium ratios by coverage from
the Statistical Agent premium data. The estimated premium impacts derived above are then applied by
coverage for each county, and the impacts are displayed for liability only and all coverages combined.
Please see Appendix 3, Pages 1 – 6 for the resulting impacts on the rate example premiums by county.


APPENDICES
1. Average Premium Change by County, No‐Fault Repeal, 25/50 Financial Responsibility Limit

2. Average Premium Change by County, No Fault Repeal, 25/50 Financial Responsibility Limit,
Current Policies with Minimum Required Coverage Only

3. By County Premium Impact Rate Examples, No‐Fault Repeal
Florida Office of Insurance Regulation Appendix 1, Page 1
The Impact of Repealing Personal Injury Protection Coverage in Florida
25/50 Financial Responsibility Limits
Statewide Average Premium Change
Repeal of No Fault

Collision 356.23 356.23

Collision 356.23 356.23

Collision 356.23 356.23
Alachua County Average Premium Change
Repeal of No Fault

Liability Subtotal 798.94 849.64 6.3%
Collision 305.90 305.90

Collision 305.90 305.90

Collision 305.90 305.90
Baker County Average Premium Change
Repeal of No Fault

Collision 311.11 311.11

Collision 311.11 311.11

Collision 311.11 311.11
Bay County Average Premium Change
Repeal of No Fault

Collision 328.13 328.13

Collision 328.13 328.13

Collision 328.13 328.13
Bradford County Average Premium Change
Repeal of No Fault

Collision 332.60 332.60

Collision 332.60 332.60

Collision 332.60 332.60
Brevard County Average Premium Change
Repeal of No Fault

Collision 281.30 281.30

Liability Subtotal 866.49 1,026.40 18.5%
Collision 281.30 281.30

Collision 281.30 281.30
Broward County Average Premium Change
Repeal of No Fault

Liability Subtotal 1,277.60 1,266.45 ‐0.9%
Collision 437.89 437.89
Total Major Coverages 1,867.13 1,855.98 ‐0.6%

Collision 437.89 437.89

Collision 437.89 437.89
Calhoun County Average Premium Change
Repeal of No Fault

Liability Subtotal 620.84 619.72 ‐0.2%
Collision 321.55 321.55

Collision 321.55 321.55

Collision 321.55 321.55
Charlotte County Average Premium Change
Repeal of No Fault

Collision 261.32 261.32

Collision 261.32 261.32

Collision 261.32 261.32
Citrus County Average Premium Change
Repeal of No Fault

Collision 257.44 257.44

Collision 257.44 257.44

Collision 257.44 257.44
Clay County Average Premium Change
Repeal of No Fault

Collision 307.07 307.07

Collision 307.07 307.07

Collision 307.07 307.07
Collier County Average Premium Change
Repeal of No Fault

Collision 312.74 312.74

Collision 312.74 312.74

Collision 312.74 312.74
Columbia County Average Premium Change
Repeal of No Fault

Collision 318.62 318.62

Collision 318.62 318.62

Collision 318.62 318.62
DeSoto County Average Premium Change
Repeal of No Fault

Collision 335.90 335.90

Collision 335.90 335.90

Collision 335.90 335.90
Dixie County Average Premium Change
Repeal of No Fault

Collision 287.59 287.59

Collision 287.59 287.59

Collision 287.59 287.59
Duval County Average Premium Change
Repeal of No Fault

Collision 375.42 375.42

Collision 375.42 375.42

Collision 375.42 375.42
Escambia County Average Premium Change
Repeal of No Fault

Collision 345.18 345.18

Collision 345.18 345.18

Collision 345.18 345.18
Flagler County Average Premium Change
Repeal of No Fault

Collision 257.94 257.94

Collision 257.94 257.94

Collision 257.94 257.94
Franklin County Average Premium Change
Repeal of No Fault

Collision 305.72 305.72

Collision 305.72 305.72

Collision 305.72 305.72
Gadsden County Average Premium Change
Repeal of No Fault

Collision 337.75 337.75

Collision 337.75 337.75

Collision 337.75 337.75
Gilchrist County Average Premium Change
Repeal of No Fault

Collision 285.53 285.53

Collision 285.53 285.53

Collision 285.53 285.53
Glades County Average Premium Change
Repeal of No Fault

Collision 364.92 364.92

Collision 364.92 364.92

Collision 364.92 364.92
Gulf County Average Premium Change
Repeal of No Fault

Collision 288.90 288.90

Collision 288.90 288.90

Collision 288.90 288.90
Hamilton County Average Premium Change
Repeal of No Fault

Collision 323.60 323.60

Collision 323.60 323.60

Collision 323.60 323.60
Hardee County Average Premium Change
Repeal of No Fault

Collision 311.41 311.41

Collision 311.41 311.41

Collision 311.41 311.41
Hendry County Average Premium Change
Repeal of No Fault

Collision 364.54 364.54

Collision 364.54 364.54

Collision 364.54 364.54
Hernando County Average Premium Change
Repeal of No Fault

Collision 299.45 299.45

Collision 299.45 299.45

Collision 299.45 299.45
Highlands County Average Premium Change
Repeal of No Fault

Collision 318.02 318.02

Collision 318.02 318.02

Collision 318.02 318.02
Hillsborough County Average Premium Change
Repeal of No Fault

Collision 376.41 376.41

Collision 376.41 376.41

Collision 376.41 376.41
Holmes County Average Premium Change
Repeal of No Fault

Collision 303.39 303.39

Collision 303.39 303.39

Collision 303.39 303.39
Indian River County Average Premium Change
Repeal of No Fault

Collision 278.83 278.83

Collision 278.83 278.83

Collision 278.83 278.83
Jackson County Average Premium Change
Repeal of No Fault

Collision 309.10 309.10

Collision 309.10 309.10

Collision 309.10 309.10
Jefferson County Average Premium Change
Repeal of No Fault

Collision 318.58 318.58

Collision 318.58 318.58

Collision 318.58 318.58
Lafayette County Average Premium Change
Repeal of No Fault

Collision 370.44 370.44

Collision 370.44 370.44

Collision 370.44 370.44
Lake County Average Premium Change
Repeal of No Fault

Collision 308.88 308.88

Collision 308.88 308.88

Collision 308.88 308.88
Lee County Average Premium Change
Repeal of No Fault

Collision 306.62 306.62

Collision 306.62 306.62

Collision 306.62 306.62
Leon County Average Premium Change
Repeal of No Fault

Collision 365.14 365.14

Collision 365.14 365.14

Collision 365.14 365.14
Levy County Average Premium Change
Repeal of No Fault

Collision 273.03 273.03

Collision 273.03 273.03

Collision 273.03 273.03
Liberty County Average Premium Change
Repeal of No Fault

Collision 328.63 328.63

Collision 328.63 328.63

Collision 328.63 328.63
Madison County Average Premium Change
Repeal of No Fault

Collision 304.68 304.68

Collision 304.68 304.68

Collision 304.68 304.68
Manatee County Average Premium Change
Repeal of No Fault

Collision 312.32 312.32

Collision 312.32 312.32

Collision 312.32 312.32
Marion County Average Premium Change
Repeal of No Fault

Collision 287.52 287.52

Collision 287.52 287.52

Collision 287.52 287.52
Martin County Average Premium Change
Repeal of No Fault

Collision 286.78 286.78

Collision 286.78 286.78

Collision 286.78 286.78
Miami‐Dade County Average Premium Change
Repeal of No Fault

Collision 497.43 497.43

Collision 497.43 497.43

Collision 497.43 497.43
Monroe County Average Premium Change
Repeal of No Fault

Collision 371.12 371.12

Collision 371.12 371.12

Collision 371.12 371.12
Nassau County Average Premium Change
Repeal of No Fault

Collision 293.28 293.28

Collision 293.28 293.28

Collision 293.28 293.28
Okaloosa County Average Premium Change
Repeal of No Fault

Collision 315.76 315.76

Collision 315.76 315.76

Collision 315.76 315.76
Okeechobee County Average Premium Change
Repeal of No Fault

Collision 314.20 314.20

Collision 314.20 314.20

Collision 314.20 314.20
Orange County Average Premium Change
Repeal of No Fault

Collision 365.84 365.84

Collision 365.84 365.84

Collision 365.84 365.84
Osceola County Average Premium Change
Repeal of No Fault

Collision 352.29 352.29

Collision 352.29 352.29

Collision 352.29 352.29
Palm Beach County Average Premium Change
Repeal of No Fault

Collision 407.13 407.13

Collision 407.13 407.13

Collision 407.13 407.13
Pasco County Average Premium Change
Repeal of No Fault

Collision 332.36 332.36

Collision 332.36 332.36

Collision 332.36 332.36
Pinellas County Average Premium Change
Repeal of No Fault

Collision 309.17 309.17

Collision 309.17 309.17

Collision 309.17 309.17
Polk County Average Premium Change
Repeal of No Fault

Collision 346.69 346.69

Collision 346.69 346.69

Collision 346.69 346.69
Putnam County Average Premium Change
Repeal of No Fault

Collision 298.55 298.55

Collision 298.55 298.55

Collision 298.55 298.55
Santa Rosa County Average Premium Change
Repeal of No Fault

Collision 313.54 313.54

Collision 313.54 313.54

Collision 313.54 313.54
Sarasota County Average Premium Change
Repeal of No Fault

Collision 287.18 287.18

Collision 287.18 287.18

Collision 287.18 287.18
Seminole County Average Premium Change
Repeal of No Fault

Collision 322.17 322.17

Collision 322.17 322.17

Collision 322.17 322.17
St. Johns County Average Premium Change
Repeal of No Fault

Collision 304.92 304.92

Collision 304.92 304.92

Collision 304.92 304.92
St. Lucie County Average Premium Change
Repeal of No Fault

Collision 297.90 297.90

Collision 297.90 297.90

Collision 297.90 297.90
Sumter County Average Premium Change
Repeal of No Fault

Collision 240.38 240.38

Collision 240.38 240.38

Collision 240.38 240.38
Suwannee County Average Premium Change
Repeal of No Fault

Collision 333.34 333.34

Collision 333.34 333.34

Collision 333.34 333.34
Taylor County Average Premium Change
Repeal of No Fault

Collision 300.79 300.79

Collision 300.79 300.79

Collision 300.79 300.79
Union County Average Premium Change
Repeal of No Fault

Collision 314.83 314.83

Collision 314.83 314.83

Collision 314.83 314.83
Volusia County Average Premium Change
Repeal of No Fault

Collision 293.83 293.83

Collision 293.83 293.83

Collision 293.83 293.83
Wakulla County Average Premium Change
Repeal of No Fault

Collision 305.84 305.84

Collision 305.84 305.84

Collision 305.84 305.84
Walton County Average Premium Change
Repeal of No Fault

Collision 306.99 306.99

Collision 306.99 306.99

Collision 306.99 306.99
Washington County Average Premium Change
Repeal of No Fault

Collision 299.75 299.75

Collision 299.75 299.75

Collision 299.75 299.75
Statewide Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Bodily Injury 553.41
Uninsured Motorist
Comprehensive
Collision
Total Major Coverages 585.06 867.69 48.3%
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Total Major Coverages 585.06 1,036.73 77.2%
Alachua County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Baker County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Bay County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Bradford County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Brevard County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Broward County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Calhoun County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Charlotte County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Citrus County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Clay County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Collier County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Columbia County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
DeSoto County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Dixie County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Duval County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Escambia County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Flagler County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Franklin County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Gadsden County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Gilchrist County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Glades County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Gulf County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Hamilton County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Hardee County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Hendry County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Hernando County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Highlands County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Hillsborough County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Holmes County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Indian River County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Jackson County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Jefferson County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Lafayette County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Lake County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Lee County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Leon County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Levy County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Liberty County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Madison County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Manatee County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Marion County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Martin County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Miami‐Dade County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Monroe County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Nassau County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Okaloosa County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Okeechobee County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Orange County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Osceola County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Palm Beach County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Pasco County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Pinellas County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Polk County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Putnam County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Santa Rosa County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Sarasota County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Seminole County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
St. Johns County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
St. Lucie County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Sumter County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Property Damage 307 307.00
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Suwannee County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Taylor County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Union County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Volusia County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Wakulla County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Walton County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Washington County Average Premium Change for Policies with Minimum Coverage
Repeal of No Fault
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Uninsured Motorist
Comprehensive
Collision
Appendix 3, Page 1
By County Premium Impacts, No‐Fault Repeal, 10/20 Financial Responsibility Limit
Senior Risk Example
Current Premium Proposed Premium Percent Change

Physical All Physical All All
County Liability Damage Coverages Liability Damage Coverages Liability Coverages
Alachua County 913 456 1,369 968 456 1,424 6.0% 4.0%
Baker County 906 518 1,424 961 518 1,479 6.1% 3.9%
Bay County 893 502 1,395 919 502 1,421 2.9% 1.9%
Bradford County 918 522 1,440 963 522 1,485 5.0% 3.2%
Brevard County 1,063 449 1,512 1,163 449 1,612 9.4% 6.6%
Broward County 1,503 662 2,165 1,490 662 2,152 -0.9% -0.6%
Calhoun County 760 597 1,357 759 597 1,356 -0.2% -0.1%
Charlotte County 985 428 1,413 1,077 428 1,505 9.4% 6.5%
Citrus County 1,026 450 1,476 1,118 450 1,568 9.0% 6.2%
Clay County 1,077 482 1,559 1,159 482 1,641 7.6% 5.3%
Collier County 1,032 492 1,524 1,117 492 1,609 8.3% 5.6%
Columbia County 851 519 1,370 872 519 1,391 2.5% 1.5%
DeSoto County 948 505 1,453 960 505 1,465 1.2% 0.8%
Dixie County 873 520 1,393 879 520 1,399 0.7% 0.5%
Duval County 1,140 554 1,694 1,156 554 1,710 1.4% 1.0%
Escambia County 991 549 1,540 1,022 549 1,571 3.1% 2.0%
Flagler County 1,015 450 1,465 1,132 450 1,582 11.5% 8.0%
Franklin County 760 546 1,306 774 546 1,320 1.9% 1.1%
Gadsden County 810 546 1,356 779 546 1,325 -3.9% -2.3%
Gilchrist County 876 481 1,357 903 481 1,384 3.1% 2.0%
Glades County 1,074 464 1,538 1,136 464 1,600 5.8% 4.1%
Gulf County 802 542 1,344 846 542 1,388 5.5% 3.3%
Hamilton County 778 569 1,347 775 569 1,344 -0.4% -0.2%
Hardee County 968 503 1,471 1,002 503 1,505 3.5% 2.3%
Hendry County 1,076 555 1,631 1,058 555 1,613 -1.7% -1.1%
Hernando County 1,327 505 1,832 1,391 505 1,896 4.8% 3.5%
Highlands County 977 492 1,469 999 492 1,491 2.2% 1.5%
Hillsborough County 1,573 630 2,203 1,589 630 2,219 1.0% 0.7%
Holmes County 751 544 1,295 768 544 1,312 2.2% 1.3%
Indian River County 1,029 433 1,462 1,152 433 1,585 11.9% 8.4%
Jackson County 785 551 1,336 824 551 1,375 4.9% 2.9%
Jefferson County 795 530 1,325 820 530 1,350 3.1% 1.9%
Lafayette County 852 499 1,351 866 499 1,365 1.6% 1.0%
Lake County 1,007 453 1,460 1,057 453 1,510 4.9% 3.4%
Lee County 1,093 487 1,580 1,168 487 1,655 6.9% 4.7%
Leon County 885 508 1,393 936 508 1,444 5.8% 3.7%
Levy County 889 458 1,347 922 458 1,380 3.7% 2.4%
Liberty County 775 570 1,345 770 570 1,340 -0.6% -0.3%
Madison County 789 570 1,359 799 570 1,369 1.2% 0.7%
Manatee County 1,118 474 1,592 1,198 474 1,672 7.2% 5.1%
Marion County 1,003 439 1,442 1,052 439 1,491 4.9% 3.4%
Martin County 1,128 432 1,560 1,299 432 1,731 15.1% 10.9%
Miami‐Dade County 1,579 868 2,447 1,422 868 2,290 -9.9% -6.4%
Monroe County 1,025 617 1,642 1,092 617 1,709 6.5% 4.1%
Appendix 3, Page 2
Senior Risk Example

Nassau County 920 512 1,432 1,013 512 1,525 10.1% 6.5%
Okaloosa County 829 520 1,349 881 520 1,401 6.3% 3.9%
Okeechobee County 1,056 512 1,568 1,094 512 1,606 3.6% 2.4%
Orange County 1,230 516 1,746 1,204 516 1,720 -2.1% -1.5%
Osceola County 1,219 485 1,704 1,166 485 1,651 -4.3% -3.1%
Palm Beach County 1,697 659 2,356 1,812 659 2,471 6.8% 4.9%
Pasco County 1,425 569 1,994 1,499 569 2,068 5.2% 3.7%
Pinellas County 1,483 533 2,016 1,609 533 2,142 8.5% 6.2%
Polk County 1,119 500 1,619 1,129 500 1,629 0.9% 0.6%
Putnam County 927 473 1,400 978 473 1,451 5.6% 3.7%
Santa Rosa County 905 533 1,438 959 533 1,492 6.0% 3.8%
Sarasota County 984 425 1,409 1,091 425 1,516 10.9% 7.6%
Seminole County 1,125 470 1,595 1,176 470 1,646 4.5% 3.2%
St. Johns County 931 458 1,389 1,059 458 1,517 13.7% 9.2%
St. Lucie County 1,228 446 1,674 1,261 446 1,707 2.7% 2.0%
Sumter County 1,010 422 1,432 1,165 422 1,587 15.3% 10.8%
Suwannee County 846 494 1,340 862 494 1,356 1.9% 1.2%
Taylor County 812 536 1,348 859 536 1,395 5.8% 3.5%
Union County 904 544 1,448 901 544 1,445 -0.4% -0.2%
Volusia County 1,040 458 1,498 1,093 458 1,551 5.1% 3.5%
Wakulla County 839 552 1,391 858 552 1,410 2.3% 1.4%
Walton County 818 515 1,333 878 515 1,393 7.3% 4.5%
Washington County 790 549 1,339 794 549 1,343 0.5% 0.3%
Appendix 3, Page 3
Single Female Risk Example

Alachua County 1,842 920 2,762 1,954 920 2,874 6.1% 4.0%
Baker County 1,938 1,111 3,049 2,055 1,111 3,166 6.0% 3.8%
Bay County 1,810 1,017 2,827 1,862 1,017 2,879 2.9% 1.9%
Bradford County 1,876 1,066 2,942 1,969 1,066 3,035 5.0% 3.2%
Brevard County 2,156 910 3,066 2,358 910 3,268 9.4% 6.6%
Broward County 3,002 1,325 4,327 2,977 1,325 4,302 -0.8% -0.6%
Calhoun County 1,624 1,278 2,902 1,621 1,278 2,899 -0.2% -0.1%
Charlotte County 2,010 876 2,886 2,197 876 3,073 9.3% 6.5%
Citrus County 2,077 913 2,990 2,264 913 3,177 9.0% 6.3%
Clay County 2,230 998 3,228 2,398 998 3,396 7.5% 5.2%
Collier County 2,055 980 3,035 2,225 980 3,205 8.2% 5.6%
Columbia County 1,812 1,104 2,916 1,857 1,104 2,961 2.5% 1.5%
DeSoto County 1,959 1,042 3,001 1,982 1,042 3,024 1.2% 0.8%
Dixie County 1,819 1,084 2,903 1,832 1,084 2,916 0.7% 0.5%
Duval County 2,356 1,146 3,502 2,390 1,146 3,536 1.4% 1.0%
Escambia County 2,039 1,130 3,169 2,104 1,130 3,234 3.2% 2.0%
Flagler County 2,075 918 2,993 2,315 918 3,233 11.5% 8.0%
Franklin County 1,592 1,142 2,734 1,621 1,142 2,763 1.8% 1.1%
Gadsden County 1,707 1,151 2,858 1,640 1,151 2,791 -3.9% -2.4%
Gilchrist County 1,828 1,003 2,831 1,883 1,003 2,886 3.0% 2.0%
Glades County 2,237 965 3,202 2,367 965 3,332 5.8% 4.1%
Gulf County 1,636 1,105 2,741 1,726 1,105 2,831 5.5% 3.3%
Hamilton County 1,634 1,194 2,828 1,626 1,194 2,820 -0.5% -0.3%
Hardee County 2,029 1,055 3,084 2,100 1,055 3,155 3.5% 2.3%
Hendry County 2,222 1,148 3,370 2,185 1,148 3,333 -1.7% -1.1%
Hernando County 2,605 992 3,597 2,730 992 3,722 4.8% 3.5%
Highlands County 1,975 995 2,970 2,020 995 3,015 2.3% 1.5%
Hillsborough County 3,182 1,273 4,455 3,216 1,273 4,489 1.1% 0.8%
Holmes County 1,597 1,157 2,754 1,632 1,157 2,789 2.2% 1.3%
Indian River County 2,056 864 2,920 2,302 864 3,166 12.0% 8.4%
Jackson County 1,664 1,168 2,832 1,745 1,168 2,913 4.9% 2.9%
Jefferson County 1,670 1,114 2,784 1,724 1,114 2,838 3.2% 1.9%
Lafayette County 1,793 1,050 2,843 1,821 1,050 2,871 1.6% 1.0%
Lake County 2,053 924 2,977 2,155 924 3,079 5.0% 3.4%
Lee County 2,217 988 3,205 2,369 988 3,357 6.9% 4.7%
Leon County 1,804 1,036 2,840 1,909 1,036 2,945 5.8% 3.7%
Levy County 1,886 971 2,857 1,955 971 2,926 3.7% 2.4%
Liberty County 1,636 1,205 2,841 1,625 1,205 2,830 -0.7% -0.4%
Madison County 1,641 1,184 2,825 1,661 1,184 2,845 1.2% 0.7%
Manatee County 2,252 956 3,208 2,414 956 3,370 7.2% 5.0%
Marion County 2,082 910 2,992 2,184 910 3,094 4.9% 3.4%
Martin County 2,292 878 3,170 2,639 878 3,517 15.2% 11.0%
Miami‐Dade County 3,200 1,759 4,959 2,883 1,759 4,642 -9.9% -6.4%
Monroe County 2,053 1,235 3,288 2,186 1,235 3,421 6.5% 4.0%
Nassau County 1,925 1,071 2,996 2,119 1,071 3,190 10.1% 6.5%
Appendix 3, Page 4
Single Female Risk Example

Okaloosa County 1,726 1,083 2,809 1,834 1,083 2,917 6.3% 3.9%
Okeechobee County 2,071 1,003 3,074 2,145 1,003 3,148 3.6% 2.4%
Orange County 2,499 1,049 3,548 2,448 1,049 3,497 -2.0% -1.4%
Osceola County 2,504 995 3,499 2,395 995 3,390 -4.4% -3.1%
Palm Beach County 3,256 1,266 4,522 3,476 1,266 4,742 6.8% 4.9%
Pasco County 2,841 1,134 3,975 2,990 1,134 4,124 5.2% 3.7%
Pinellas County 2,911 1,046 3,957 3,158 1,046 4,204 8.5% 6.2%
Polk County 2,279 1,020 3,299 2,299 1,020 3,319 0.9% 0.6%
Putnam County 1,990 1,014 3,004 2,100 1,014 3,114 5.5% 3.7%
Santa Rosa County 1,892 1,116 3,008 2,004 1,116 3,120 5.9% 3.7%
Sarasota County 2,034 878 2,912 2,255 878 3,133 10.9% 7.6%
Seminole County 2,279 954 3,233 2,382 954 3,336 4.5% 3.2%
St. Johns County 1,919 944 2,863 2,181 944 3,125 13.7% 9.2%
St. Lucie County 2,460 894 3,354 2,528 894 3,422 2.8% 2.0%
Sumter County 2,112 882 2,994 2,437 882 3,319 15.4% 10.8%
Suwannee County 1,778 1,038 2,816 1,811 1,038 2,849 1.9% 1.2%
Taylor County 1,707 1,126 2,833 1,804 1,126 2,930 5.7% 3.4%
Union County 1,821 1,098 2,919 1,815 1,098 2,913 -0.3% -0.2%
Volusia County 2,130 938 3,068 2,239 938 3,177 5.1% 3.5%
Wakulla County 1,745 1,148 2,893 1,785 1,148 2,933 2.3% 1.4%
Walton County 1,772 1,114 2,886 1,901 1,114 3,015 7.3% 4.5%
Washington County 1,692 1,176 2,868 1,700 1,176 2,876 0.5% 0.3%
Appendix 3, Page 5
Family Risk Example

Alachua County 4,804 2,399 7,203 5,096 2,399 7,495 6.1% 4.0%
Baker County 4,704 2,695 7,399 4,988 2,695 7,683 6.0% 3.8%
Bay County 4,967 2,790 7,757 5,111 2,790 7,901 2.9% 1.9%
Bradford County 4,953 2,815 7,768 5,198 2,815 8,013 5.0% 3.2%
Brevard County 5,520 2,330 7,850 6,038 2,330 8,368 9.4% 6.6%
Broward County 7,909 3,487 11,396 7,843 3,487 11,330 -0.8% -0.6%
Calhoun County 4,032 3,171 7,203 4,025 3,171 7,196 -0.2% -0.1%
Charlotte County 5,232 2,276 7,508 5,718 2,276 7,994 9.3% 6.5%
Citrus County 5,369 2,357 7,726 5,852 2,357 8,209 9.0% 6.3%
Clay County 5,724 2,560 8,284 6,157 2,560 8,717 7.6% 5.2%
Collier County 5,498 2,621 8,119 5,951 2,621 8,572 8.2% 5.6%
Columbia County 4,500 2,744 7,244 4,613 2,744 7,357 2.5% 1.6%
DeSoto County 4,987 2,654 7,641 5,048 2,654 7,702 1.2% 0.8%
Dixie County 4,778 2,847 7,625 4,812 2,847 7,659 0.7% 0.5%
Duval County 6,118 2,975 9,093 6,206 2,975 9,181 1.4% 1.0%
Escambia County 5,472 3,034 8,506 5,646 3,034 8,680 3.2% 2.0%
Flagler County 5,336 2,363 7,699 5,951 2,363 8,314 11.5% 8.0%
Franklin County 4,105 2,946 7,051 4,181 2,946 7,127 1.8% 1.1%
Gadsden County 4,306 2,906 7,212 4,137 2,906 7,043 -3.9% -2.3%
Gilchrist County 4,631 2,543 7,174 4,773 2,543 7,316 3.1% 2.0%
Glades County 5,554 2,396 7,950 5,876 2,396 8,272 5.8% 4.0%
Gulf County 4,458 3,012 7,470 4,703 3,012 7,715 5.5% 3.3%
Hamilton County 4,131 3,020 7,151 4,113 3,020 7,133 -0.4% -0.3%
Hardee County 4,929 2,561 7,490 5,103 2,561 7,664 3.5% 2.3%
Hendry County 5,565 2,874 8,439 5,472 2,874 8,346 -1.7% -1.1%
Hernando County 6,890 2,625 9,515 7,219 2,625 9,844 4.8% 3.5%
Highlands County 5,181 2,609 7,790 5,299 2,609 7,908 2.3% 1.5%
Hillsborough County 8,094 3,240 11,334 8,180 3,240 11,420 1.1% 0.8%
Holmes County 4,008 2,905 6,913 4,095 2,905 7,000 2.2% 1.3%
Indian River County 5,283 2,221 7,504 5,917 2,221 8,138 12.0% 8.4%
Jackson County 4,203 2,950 7,153 4,409 2,950 7,359 4.9% 2.9%
Jefferson County 4,265 2,848 7,113 4,403 2,848 7,251 3.2% 1.9%
Lafayette County 4,537 2,656 7,193 4,610 2,656 7,266 1.6% 1.0%
Lake County 5,282 2,375 7,657 5,545 2,375 7,920 5.0% 3.4%
Lee County 5,808 2,589 8,397 6,207 2,589 8,796 6.9% 4.8%
Leon County 4,869 2,795 7,664 5,153 2,795 7,948 5.8% 3.7%
Levy County 4,631 2,388 7,019 4,800 2,388 7,188 3.6% 2.4%
Liberty County 4,226 3,111 7,337 4,201 3,111 7,312 -0.6% -0.3%
Madison County 4,273 3,084 7,357 4,326 3,084 7,410 1.2% 0.7%
Manatee County 5,881 2,498 8,379 6,305 2,498 8,803 7.2% 5.1%
Marion County 5,196 2,270 7,466 5,450 2,270 7,720 4.9% 3.4%
Martin County 5,720 2,190 7,910 6,587 2,190 8,777 15.2% 11.0%
Miami‐Dade County 8,301 4,566 12,867 7,478 4,566 12,044 -9.9% -6.4%
Monroe County 5,712 3,436 9,148 6,080 3,436 9,516 6.4% 4.0%
Nassau County 4,909 2,732 7,641 5,404 2,732 8,136 10.1% 6.5%
Okaloosa County 4,588 2,878 7,466 4,878 2,878 7,756 6.3% 3.9%
Appendix 3, Page 6
Family Risk Example

Okeechobee County 5,615 2,719 8,334 5,816 2,719 8,535 3.6% 2.4%
Orange County 6,419 2,695 9,114 6,288 2,695 8,983 -2.0% -1.4%
Osceola County 6,126 2,435 8,561 5,860 2,435 8,295 -4.3% -3.1%
Palm Beach County 8,859 3,445 12,304 9,459 3,445 12,904 6.8% 4.9%
Pasco County 7,265 2,901 10,166 7,644 2,901 10,545 5.2% 3.7%
Pinellas County 7,553 2,716 10,269 8,195 2,716 10,911 8.5% 6.2%
Polk County 5,859 2,621 8,480 5,910 2,621 8,531 0.9% 0.6%
Putnam County 4,799 2,447 7,246 5,064 2,447 7,511 5.5% 3.7%
Santa Rosa County 4,933 2,910 7,843 5,225 2,910 8,135 5.9% 3.7%
Sarasota County 5,180 2,237 7,417 5,744 2,237 7,981 10.9% 7.6%
Seminole County 5,971 2,501 8,472 6,242 2,501 8,743 4.5% 3.2%
St. Johns County 4,935 2,427 7,362 5,610 2,427 8,037 13.7% 9.2%
St. Lucie County 6,201 2,254 8,455 6,371 2,254 8,625 2.7% 2.0%
Sumter County 5,251 2,194 7,445 6,058 2,194 8,252 15.4% 10.8%
Suwannee County 4,442 2,594 7,036 4,525 2,594 7,119 1.9% 1.2%
Taylor County 4,341 2,864 7,205 4,590 2,864 7,454 5.7% 3.5%
Union County 4,927 2,969 7,896 4,909 2,969 7,878 -0.4% -0.2%
Volusia County 5,413 2,384 7,797 5,690 2,384 8,074 5.1% 3.6%
Wakulla County 4,569 3,006 7,575 4,672 3,006 7,678 2.3% 1.4%
Walton County 4,424 2,782 7,206 4,745 2,782 7,527 7.3% 4.5%
Washington County 4,214 2,930 7,144 4,233 2,930 7,163 0.4% 0.3%
Appendix 3, Page 7
Rate Examples
Senior Married Couple Single Female Family with Young Drivers

Married Male Age 70, Married Female Age 65 Single Female Age 25 Married Male Age 50, Married Female Age 50, Single Male Age 20,
Age/Sex/Marital Status Single Female Age 18
Policy Term One Year One Year One Year
Policy Tenure Has continuously renewed policy with company for prior five years New Business New Business
Prior Insurance Proof Available for Preceding Five Years Proof Available for Preceding Year Proof Available for Preceding 3 Years
Coverages, Limits (in 000's) Bodily Injury - Limit of $50/$100 Bodily Injury - Limit of $25/$50 Bodily Injury - Limit of $25/$50
and Deductible Purchased Property Damage - Limit of $100 Property Damage - Limit of $50 Property Damage - Limit of $50
Personal Injury Protection - Limit of $10, No Ded. Personal Injury Protection - Limit of $10, No Ded. Personal Injury Protection - Limit of $10, No Ded.
Medical Payments - Limit of $5 Medical Payments - Limit of $5 Medical Payments - Limit of $5
Uninsured Motorists - Limit of $50/$100 (Non-Stacked) Uninsured Motorists - Limit of $25/$50 (Non-Stacked) Uninsured Motorists - Limit of $25/$50 (Non-Stacked)
Comprehensive - Deductible of $250 Comprehensive - Deductible of $250 Comprehensive - Deductible of $250
Collision - Deductible of $500 Collision - Deductible of $500 Collision - Deductible of $500
Limits Purchased History Unchanged for prior 3 years Unchanged for prior 3 years Unchanged for prior 3 years
Number of Cars One One Two, Camry driven equally by each of the males, Corolla driven equally
by each of the females
Experience of Operators No violations or accident involvement in past 3 years One minor violation and one not-at-fault accident in prior 3 years, No violations or accident involvement in past 3 years
licensed at age 16
Use and Mileage Pleasure use, 6,000 miles per year Camry driven to work 12 road miles each way, 12,000 miles per year Camry driven to work 12 road miles each way, 12,000 miles per year,
Corolla pleasure use, 8,000 miles per year
Insurance Credit Score 80th Percentile 50th Percentile 80th Percentile
Make and Model of Car Toyota Camry LE Toyota Camry LE Toyota Camry LE, Toyota Corolla LE
Age of Car Five model years old (2007 as of October 1, 2011, etc.) Latest model year (2012 as of October 1, 2011, etc.) Camry - Latest model year (2012 as of October 1, 2011, etc.) and
Corolla - Five model years old
Safety Devices Drivers Side Airbag Drivers Side Airbag Drivers Side Airbag
Additional Discounts Paid In Full, Homeowner None None

Florida OIR PIP Repeal Impact Final Report

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Florida OIR PIP Repeal Impact Final Report

Uploaded by

Copyright:

Available Formats

Minimum 25/50 None 48.3% 48.3%

(6) Estimated Non‐Economic Loss For Claims That do not Qualify for Tort Recovery 172,750

(1) (2) (3) (4) (5)

(1) (2) (3) (4) (5)

143 $1,872,010 $13,091

(1) (2) (3) (4) (5)

Year‐ending Frequency Severity Loss Cost

June 1977 1.89 6,602 12.47

September 1977 1.63 7,676 12.49

December 1977 1.62 7,676 12.47

March 1978 1.58 7,179 11.32

June 1978 1.70 8,016 13.59

Average 1.68 7,430 12.47

State Date of No‐Fault Repeal Dollar Threshold

Nevada 01/01/1980 $750

Georgia 10/01/1991 $500

Connecticut 01/01/1994 $400

Colorado 07/01/2003 $2,500

Year Pure Paid Claim Paid Claim Pure Paid Claim Paid Claim

(1) (2) (3) (4) (5) (6) (7)

Total 779 $5,023,908 $2,818,454 $4,580,688 0.56 0.91

(1) (2) (3) (4) (5) (6) (7)

Total 713 $4,416,104 $2,562,954 $4,138,348 0.51 0.82

Bodily Injury 369.04 622.70

Bodily Injury 369.04 622.70

Bodily Injury 369.04 622.70

(1) (2) (3) (4) = (3) / (2)

Total Tort States 61,902,245 93,572,391 66.2%

Qualifies 239 $1,967,902 $8,234 43.2%

Doesn't Qualify 427 $2,583,360 $6,050 56.8%

Total 666 $4,634,448 $6,834

Medical Paid Average Medical

143 $984,223 $6,882

(1) Total Florida Paid PIP Medical Loss 2,734,628,730 (A.M Best Page 14 PIP Paid Losses, Florida, 2019 ) * .93

(14) Percentage of Drivers At‐fault 35.60% 1.0 ‐ (2)

(18) Total Not Recovered from auto insurance 362,991,509 (13) + (17)

Single Car Accidents 18.6% 18.4%

2 Car Accidents 68.2% 68.1%

3 or more Car Accidents 13.1% 13.5%

1 43.8% 25.3% 30.9%

2 86.9% 10.0% 3.1%

3 or more 90.9% 9.1% 0.0%

(1) (2) (3) (4) = (3) / (2) (5) = (3) / (3) Total

Insured 481 3,391,990 7,052 67.5%

Family Member 170 1,017,906 5,988 20.3%

Other/Unknown 127 612,588 4,824 12.2%

Total 778 5,022,484

Cars Involved (5) (6) (7) (8)

(1) Total Florida Paid PIP Medical Loss 2,734,628,730 (A.M Best Page 14 PIP Paid Losses, Florida, 2019 ) * .93

(14) Percentage of Drivers At‐fault 50.10% 1.0 ‐ (2)

(18) Total Not Recovered from auto insurance 476,751,915 (13) + (17)

PIP Medical PIP Medical Percent

Single $7,296 1 car $29.62 0.4% $38.96 0.5%

$20,593 1 car $29.62 0.1% $38.96 0.2%

Family $20,593 2 cars $59.24 0.3% $77.92 0.4%

$20,593 3 cars $88.86 0.4% $116.88 0.6%

Bodily Injury 369.04 622.70

Bodily Injury 369.04 622.70

Bodily Injury 369.04 622.70

Bodily Injury 288.87 487.42

Bodily Injury 288.87 487.42

Bodily Injury 288.87 487.42

Bodily Injury 275.63 465.08

Bodily Injury 275.63 465.08