Deputy Director, Insurance, Compliance and Reporting (ICR)

Division Operations, Workforce Management, and Quality Control

• Directs the daily operations of the Insurance, Compliance and Reporting Division and provides direct supervision to Division employees assigned to self-insurance, employer compliance, insurance reporting, certificate-of-compliance, and administrative functions.
• Develops operational work plans, establishes priorities and deadlines, assigns and reviews work, monitors workload distribution, and reallocates staff resources in response to changes in risk, filing volume, statutory deadlines, Commission priorities, and employee availability.
• Establishes standards for the quality, consistency, documentation, and timeliness of Division work products. Reviews complex staff analyses, correspondence, compliance actions, financial evaluations, hearing materials, and recommendations before submission to the Director.
• Exercises the full range of supervisory responsibilities, including employee selection, onboarding, training, coaching, performance evaluation, leave approval, performance improvement, disciplinary recommendations, succession planning, and professional development.
• Identifies deficiencies in procedures, staff capacity, technical knowledge, internal controls, or program performance and implements corrective measures. Promotes cross-training to ensure continuity of critical regulatory operations and reduces dependence on individual employees for specialized program knowledge.
• Develops written procedures, review protocols, templates, risk-rating methodologies, performance measures, and workflow controls. Ensures that staff consistently apply applicable laws, regulations, Commission orders, Division policies, accounting principles, and regulatory standards.
• Provides the Director with regular reports concerning workload, staffing, compliance activity, high-risk self-insurers, unresolved cases, program performance, operational barriers, and matters requiring executive or Commission action.
   

Financial Risk Oversight of Active and Prospective Self-Insured Employers

• Manages the Division’s comprehensive financial oversight program for employers applying for or authorized to maintain workers’ compensation self-insurance in Maryland.
• Directs and performs advanced analysis of audited financial statements, interim financial statements, cash-flow information, debt agreements, credit reports, actuarial reports, claims data, loss-development information, reserve adequacy, corporate guarantees, excess insurance policies, security instruments, and other relevant information.
• Evaluates financial strength using liquidity, leverage, profitability, solvency, cash-flow, working-capital, debt-service, reserve-development, and industry-specific measures. Determines whether financial trends or operating conditions indicate an increased risk that an employer may be unable to satisfy its workers’ compensation obligations.
• Establishes enhanced monitoring requirements for employers demonstrating financial weakness or increased risk. Such monitoring may include monthly or quarterly financial reporting, revised actuarial reporting, updated claims information, liquidity certifications, debt-covenant information, credit-rating reports, corporate restructuring information, and other supplemental documentation.
• Monitors economic, financial, and industry developments affecting self-insured employers, including bankruptcies, mergers and acquisitions, divestitures, restructuring activities, covenant violations, accounting irregularities, regulatory investigations, credit downgrades, adverse audit opinions, significant market-value deterioration, labor disruptions, operational closures, and other events that may affect an employer’s ability to pay claims.
• Develops recommendations concerning security deposits, bonds, letters of credit, securities, parental guarantees, excess insurance coverage, self-insured retention levels, financial reporting requirements, corrective-action plans, conditional approvals, suspensions, or termination of self-insurance authority.
• Communicates directly with chief financial officers, controllers, general counsel, risk managers, actuaries, auditors, brokers, financial institutions, sureties, excess insurance carriers, third-party administrators, and other corporate representatives to obtain information, resolve discrepancies, negotiate corrective actions, and communicate regulatory expectations.
• Prepares comprehensive financial risk memoranda and recommendations for the Director and the Commission. Clearly identifies material financial risks, alternative regulatory actions, potential consequences, and the recommended action necessary to protect injured workers and the workers’ compensation system.
   

Self-Insurance Program Administration and Regulatory Actions

• Manages the operational administration of the self-insurance program from initial application through continuing authorization and final termination.
• Directs the review of applications for individual and governmental group self-insurance, additions or removals of subsidiaries, corporate reorganizations, mergers, name changes, changes in third-party administrators, requests for changes in retention, replacement or modification of security, excess insurance changes, parental guarantees, and other actions requiring Commission approval.
• Ensures that application and continuing-approval packages include complete financial, actuarial, claims, insurance, legal, and organizational documentation. Determines whether additional information, security, insurance protection, financial conditions, or legal safeguards are required.
• Directs the annual review of self-insured claims information and accountability reports.
• Evaluates trends in claim frequency, severity, reserves, open claims, paid losses, incurred losses, excess recoveries, and administrative practices. Determines whether changes in claims experience warrant additional financial review, audit activity, security, insurance coverage, or regulatory action.
• Assists the Director in developing and administering audit and actuarial-review contracts relating to self-insured employers and other Division programs.
  Recommends entities for audit based on financial risk, claims activity, prior findings, reporting deficiencies, elapsed time since the prior audit, or other risk indicators. Reviews audit scopes, contractor work products, findings, corrective-action plans, and employer responses.
• Develops proposed recommendations, conditions, correspondence, and supporting documentation for Commission consideration. Coordinates with the Office of the Attorney General concerning legal instruments, regulatory interpretation, enforcement matters, Commission orders, and actions involving noncompliance.
• Tracks the implementation of Commission orders and ensures that self-insured employers, sureties, financial institutions, excess carriers, third-party administrators, and other parties satisfy all conditions within required timeframes.
• Resolves complex program issues within delegated authority and promptly escalates matters involving significant financial exposure, legal precedent, policy implications, or potential Commission action to the Director.
   

Employer Compliance and Coverage Enforcement

• Manages the daily execution of the Commission’s Employer Compliance Program, which identifies and addresses employers that may be operating without workers’ compensation insurance required by Maryland law.
• Establishes case-review, investigation, notice, hearing-referral, and follow-up procedures. Assigns cases to staff, reviews evidence, monitors case aging, and ensures consistent treatment of employers.
• Coordinates the comparison and analysis of Commission coverage information with employer, payroll, unemployment insurance, licensing, registration, and other governmental data to identify employers that may lack required coverage.
• Directs staff communications with employers, insurers, insurance producers, attorneys, accountants, payroll providers, licensing agencies, and other parties to verify coverage, clarify legal obligations, and obtain documentation.
• Determines whether available information supports case closure, additional investigation, referral for a Commission hearing, legal review, or another enforcement action. Reviews hearing files to ensure that evidence is complete, reliable, and appropriately documented.
• Coordinates operational compliance activities with the Department of Labor, Maryland Insurance Administration, governmental licensing authorities, the Office of the Attorney General, and other State or local agencies.
• Analyzes compliance trends, repeat violations, industries with elevated noncompliance, data limitations, and procedural barriers. Recommends policy, process, technology, regulatory, or legislative changes to strengthen the Commission’s ability to identify uninsured employers and obtain timely compliance.