Tag Archives: hunt

How to Improve Stress Testing

In spring 2016, PwC investigated the current state and future direction of stress testing. We surveyed 55 insurers operating in the US about their stress testing framework and the specific stresses that they test. We also engaged in more detailed dialogue with a number of insurers in the US and globally, as well as with some North American insurance regulators. Our principal conclusion is that stress testing, though well established, would benefit significantly from a modest amount of additional effort. Borrowing terminology from the Pareto principle, we think less than 20 percent more effort would yield 80 percent more value.

A brief history

Thanks to the requirements of the Dodd Frank Act of 2010, we expect that stress testing is the most widely recognized and understood risk management tool. The basic concept is relatively simple and most people in business and government readily accept the notion that if a specified future unfolded –say a repeat of the last economic crisis –it would be good to know ahead of time if banks would remain financially viable. After its initial introduction, stress testing continues to maintain a high level of attention via the ongoing publication of results from the Federal Reserve Board’s Comprehensive Capital Analysis and Review (CCAR) which the media, financial commentators, and the banks themselves eagerly anticipate.

It is easy to see how stress testing concepts in the Dodd Frank Act could apply to insurers. And, indeed the insurance industry (more specifically, its actuaries) has widely used stress testing and scenario analysis for decades.

More recently, 2013 was especially noteworthy for insurance stress testing, with publications on the subject by the North American CRO Council, the CRO Forum and the International Actuarial Association. From a regulatory perspective, the National Association of Insurance Commissioner’s (NAIC’s) Own Risk and Solvency Assessment (ORSA) calls for a prospective solvency assessment to ascertain that the insurer has the necessary available capital to meet current and projected risk capital requirements under both normal and stressed environments. In Canada, the Office of the Superintendent of Financial Institutions (OSFI) has provided clear direction on stress testing governance and methodology in its 2009 publication on Sound Business and Financial Practices (Guideline E-18). It also is noteworthy that, in Europe, despite all of the attention lavished on Solvency II and internal capital models, the European Insurance and Occupational Pensions Authority (EIOPA) launched a Europe-wide stress test for the insurance sector in May 2016.

Equally as important as the regulatory initiatives are the business applications and benefits of stress testing. As we address in more detail below, survey results show that insurers make good use of this risk management tool and are looking to expand its application even further.

A little more effort

We see three areas where only a little more effort can yield substantial benefit: 1) a clearer definition of stress testing, 2) more thoughtful stress construction, and 3) a more robust stress testing platform.

As a start, it will be useful to clarify what we mean by stress testing. As we use the term here, we mean a projection of income statements, balance sheets and –most importantly –projected available and required capital over a multiyear business planning timeframe (including new business over the planning timeframe). Typically the test is done for the entire enterprise and includes a base case and a number of stressed future states. This definition of stress testing is consistent with how both insurance (ORSA Guidance Manual) and banking (FRB CCAR) regulators use the term. It contrasts with risk-specific stress testing. Risk-specific stress testing typically looks at a single risk, often only for the part of the enterprise susceptible to that risk. And, it frequently assesses the impact over a range of stochastically determined scenarios. Distinguishing between stress testing and risk-specific stress testing needs little effort but can help companies avoid considerable confusion as they enhance and apply stress testing capabilities. Only with clear definitions can an insurer evaluate whether or not it has deployed the tool effectively. A vague notion of stress testing taking place somewhere in the organization typically means that there is unawareness of potential gaps in the enterprise risk management (ERM) framework.

See also: The Key Role for Stress Tests in ERM

Another area where we believe a little more attention would pay major benefits is the development of comprehensive stress scenarios. When describing future states, insurers have many factors to consider in order to articulate the risks that can impact their business. As an indication of the range of these factors, the section of our survey that addressed stresses had 32 questions, many with sub-parts, each covering a different risk. However, rather than starting with an effort to combine all of these risks, stress testing benefits from starting instead with a narrative that articulates a potential future and then addresses how that future would impact the insurer through various risk factors. For example, a stress narrative could be based on a prognosis of an ongoing steady decline in the price of oil and other commodities, then a postulation of the resulting impact on economic growth, interest rates, equity valuation, employment rate, etc. The narrative then could move to an analysis of the impact of these factors on the insurer’s risks, leading to a projection of how the company’s income statement, balance sheet, available and required capital would fare if this future, in fact, unfolded.

Lastly, we note that despite the considerable attention and utilization of stress testing as a management tool, it appears that, for many insurers, the infrastructure that produces results is ad hoc and likely inefficient. Our survey indicates that only 10% of respondents have built a bespoke platform for stress testing. 78% of them use spreadsheets alone or spreadsheets combined with actuarial/projection software. In terms of how long it takes to conduct stress tests, 42% of respondents indicate the process takes between one and two months. A further 35% report that it takes more than two months, and sometimes longer than three months.

While systems infrastructure updates do not normally result in major improvements from little effort, many insurers, particularly in the life sector, have already embarked on a process of modernization. As they are looking to address their risk, actuarial, and financial reporting needs in a comprehensive manner, we recommend that stress testing capabilities receive high priority. With a modest amount of extra effort, insurers should be able to incorporate significant enhancement to their stress testing platform as part of this modernization. This in turn will yield the benefit of more timely, accurate and insightful stress testing results.

A lot more value

Insurers already use their stress testing for many purposes. Survey results show that respondents currently utilize their stress testing for an average of almost five different uses. Additionally, respondents indicated they each had plans to add almost four new uses in the future. More than half of the respondents reported using their stress testing work for strategic planning, calibrating their risk tolerances and limits, assisting with dividend, share-repurchase and similar capital planning, and regulatory impact assessments. These are critical business decisions and further highlight the value of stress testing.

Furthermore, stress testing usage has had a positive impact at a significant majority of respondents’ companies. 36% reported instances where key decisions have been made very differently compared to the process prior to stress testing. An additional 29% reported that the results of stress testing has a measureable influence on decision making, though no specific decisions were cited.  

See also: New Approach to Risk and Infrastructure?

More benefits

We see a few additional areas where better articulated stress testing processes and procedures could result in significant benefits.

  • Recognize that stress testing is a separate tool in the risk manager’s tool kit–Frequently, publications and discussions on insurance stress testing describe it as something that supplements other risk management tools. We believe that relegating stress testing to supplementary status undervalues its benefits and contribution. It would be more productive to recognize stress testing for what it truly is: a separate tool with different strengths and applicability compared to VAR-based economic capital.

Some risks –for example, liquidity risk –can be addressed only via a stress test. Adding more required capital does not effectively address the problem; liquidity risk needs to be addressed by developing a preplanned course of action, including accessing prearranged liquid funds. Likewise, reputational risk –and in particular the reputational impact of a cyber event –is better addressed via the stress test tool than via the economic capital route (and the potential addition of more required capital).

Similarly, for some risks where economic capital looks like a satisfactory tool, it can give misleading information. Often pertinent risks only reveal themselves fully via stress testing. New business is a good example. Economic capital can include one or more years of new business, typically by assuming new business premium, claims, expenses, etc. are a replica of previous years’ values. But this fails to provide a platform to study how external factors could impact the insurer’s fundamental business model, leading to little or no sales of any new business that resembles prior years’ business.

Lastly, we note that most other measures, especially traditional economic capital, concern themselves primarily with very extreme, “in the tail” events. Stress testing is useful not only for high impact, low probability events. More likely events warrant attention –in fact, they may warrant more attention because they often represent more tangible and practical problems that management needs to address immediately.

  • Use stress testing to “war game” management action and prepare in advance for risk crises –In our survey, we asked insurers if stress testing incorporates management actions. In other words, as stress events unfold, presumably management would take some form of corrective action in response, and that corrective action would impact future financial results. Almost half said they do not incorporate management actions. We believe this is a significant oversight.

Stress testing provides a ready platform to prepare in advance for risk crises. Insurers can use the tool to test different responses and select the one that yields the most effective resolution. They then can put in place a contingency plan and pre-event corrections appropriate to the event.

Here again stress testing can provide a different perspective than economic capital and similar measures. Economic capital works well as a tool to quantify the impact of taking certain types of action in the present. For example, it can help determine the reduction in required capital if a particular reinsurance treaty were implemented. On the other hand, faced with a multifactor, multiyear stress event (perhaps including changes in interest rates, inflation and equity values, with increases in unemployment and deteriorating buying patterns), stress testing would be a more effective tool in judging if and when to reconfigure the asset portfolio, alter products and prices, and the cost and manner of reconfiguring staffing models.

It is worth noting that, in our discussions with regulators about the merits of including the impact of management actions, their expectations are that, yes, insurers should include them. They recognize the benefit that stress testing can provide as an opportunity for planning ahead. However, they indicated that it would be appropriate to show the stressed result both before and after the application of management action. Showing both results can help promote thoughtfully developed post-management action results, not just a broad assumption that management will take appropriate actions.

  • Take advantage of the board’s and senior management’s broad business insights to construct more insightful stress narratives –Our survey shows that most boards receive the results of the stress test either directly or via the risk committee of the board. However, only 11% report asking either the board or board risk committee to approve the stresses the company uses. We believe this represents a missed opportunity to gain board members’ insights and benefit from their engagement in the stress testing process. Not all directors will necessarily have detailed knowledge of the range of potential outcomes of all of the risks that can impact an insurer or the potential stochastic distributions of those risks, but directors typically are experienced and knowledgeable, often with a high level of business and economic acumen. Utilizing their individual and collective skills to contribute ideas on the types of stresses that merit study seems like a good fit for their role and an effective complement to managements’ efforts.
  • Stress testing represents a potential avenue for global capital consistency –As a final potential benefit, we note again that stress testing seems to have a role in all major insurance and other financial services regulatory regimes. At the same time, the global insurance industry is challenged by the task of agreeing to a capital adequacy ratio, presumably based on an economic capital VAR-like foundation. A simpler capital formulation coupled with a robust stress testing regime may hold more promise for a globally agreeable approach.

See also: Key Regulatory Issues in 2016 (Part 2)

A bright future

Based on survey results and various discussions we had with insurers and other stakeholders, stress testing is universally accepted as a useful tool. We suspect that this is a consequence of its being directly related to the common business practice of preparing a financial plan. Including a few more future states or stresses and incorporating a measure of required and available capital in the financial plan are not major steps. Accordingly, the transition from planning to stress testing should be easy to accommodate. We note how sharply this contrasts with the introduction of economic capital, especially in the US insurance industry. Though its usage is growing, economic capital is not a uniformly accepted regulatory and business tool even after two decades. On the other hand, stress testing is already actively and universally used as a management and regulatory tool. With a little more effort, we believe it can yield very substantial benefits for all.

Modernization: CRO Faces New ‘Unknowns’

Internal and external demands have resulted in the clarification and expansion of the role of the chief risk officer and the risk management function. Internally, senior management and the board see the merit of using key risk information. Ensuring the company is managed within its risk appetite enables it to best utilize its resources to take advantage of changing competitive needs and strategic opportunities. Externally, U.S. and global regulators are articulating clear expectations for the role of the CRO and governance of the risk function, as well as the role of the board in risk management and the CRO’s and risk function’s relationship with the board. These demands emphasize the need for clear policies and processes with appropriate documentation and governance.

As little as 10 years ago, the risk function was novel at most companies, and there were almost as many models of how to organize and manage the function as there were insurers. This has changed. Leading practice is becoming clearer, and expectations are now more consistent and defined. However, boards and regulators are increasingly inquiring about new “unknowns”: data security, cyber terrorism, reputational risk and competitive obsolescence. All of these also fall under the CRO’s purview and increase demands on risk resources.

The case for change

The risk function is the newest among the direct stakeholders that insurance modernization directly affects, and there are a number of important implications and outcomes.

  • No existing “pipes” – For the majority of North American risk functions, many risk calculations and resulting reports are very recent creations. Very few have a solid network of pipes that transmit data and input through models and calculations onward to result in verifiable and controlled information. Therefore, compared with many other functions that modernization affects, the risk function does not need to dismantle existing pipes. However, it is critically important that, as insurers plan and develop these new pipes, they do so in cooperation with other stakeholders. If they do not, then the risk function may find itself unnecessarily tearing up what should be a common roadway.
  • From build to oversee – While internal and external changes affect all stakeholders, the risk function is unique in that its very nature also is changing. When the risk function originally came into being, it was the CRO’s and his staff’s responsibility to create the models and capability needed to support the function. Now, as risk infrastructure takes shape, management, boards and other stakeholders are asking the CRO and risk function to play a key role in governance and control. This brings into question how best to manage and oversee both the risk and overall corporate infrastructure. Can and should these be responsibilities of the risk function, and, if not, who should be responsible for managing this infrastructure?
  • Process and documentation – Much of the newly built infrastructure was constructed quickly and in a “learn by doing” mode. Much of it is parallel to but not coordinated with activity in other areas, especially actuarial. As companies have mapped processes and documented assumptions, models and output, functional overlaps have become clearer. In many cases, clarification and resolution of the overlaps will be necessary to enable rational enterprise level mapping and non-duplicative documentation.
  • Demonstrated engagement – The CRO and risk management staff (with input from actuarial, investment, finance and others) support the foundation on which risk information is built Increasingly, the board and regulators are asking for holistic engagement in agreeing on assumptions and methodologies, not just siloed input from subject-matter experts. The risk function increasingly is being asked: Are the business managers – the first line of defense –in agreement? And, is their collective engagement substantive and verifiable?
  • Governance – As the board’s role in risk management and risk taking becomes clearer, many boards and regulators recognize the need to include major risk and strategic initiatives under the oversight umbrella. They look to the CRO to be the conduit of information between them and the insurer. This strongly suggests that the CRO should have insight into modernization initiatives that go beyond just the risk function.

In a modernized company, a synergy of efficient processes with clearly defined stakeholder expectations exists among risk, actuarial, finance and technology (RAFT). The modernized risk function will share a common foundation of data, methods and assumptions and tools and technology with the other RAFT functions. (Naturally, the risk function will have certain unique processes that build on this foundation.) Finally, enterprise compatible business management, HR, reporting and governance all channel the process to its apex: intelligent decision making.

  • Data – The organization, with significant risk input, clearly defines its data strategy via integrated information from commonly recognized sources. The goal of this strategy is information that users can extract and manipulate with minimal manual intervention at a sufficient level of detail to allow for on-demand analysis.
  • Methods and analysis – Modern risk organizations emphasize robust methods and analysis, particularly the utilization of different approaches to arrive at insight from more than one perspective. Key to proper utilization of multiple methods is confidence that different outcomes are not the result of inconsistent inputs but rather truly reflect new insight.
  • Tools and technology – Up-to-date tools and technology help the risk function gather, analyze and share information faster, more accurately and more transparently than ad hoc end-user computing analysis. With modern tools and technology, risk personnel can devote the majority of their time to understanding and managing risk rather than programming and running risk models.
  • Stress testing – Stress testing has become a key weapon in the risk management arsenal. Test results convey risk information to senior management, the board and regulators. Resulting impacts on capital under stress scenarios become key to capital planning and calibrating economic capital (EC) models. Moreover, these tests are fully integrated in financial planning and the finance function’s agenda.
  • EC/Capital modeling – Economic capital calculations continue to be an important tool for decisions at all levels, from strategic to micro-level asset trading and product design. A modernized organization fully integrates these models with key actuarial activities, and the process and results help the company more effectively plan for and manage risk. Results are available quickly, and efficiency of the process allows for extensive “what if” testing.
  • Validation – A comprehensive model risk management structure is in place. The company routinely validates new models and model changes. Assumption consistency is transparent across risk, actuarial and finance. The company verifies data integrity and uses a model inventory to weed out duplication and overlap. Savings more than pay for model risk management (MRM) costs.
  • Human capital – Risk functions employ more inquisitive and analytical analysts. The emphasis is on managing risk, not running models. A significant portion of the group devotes its time to understanding emerging trends and investigating potential new threats to the organization. Clear organizational design facilitates working in a collaborative manner with other control functions and business managers.
  • Governance – Risk plays a key role in governance and risk appetite is well established. Decision making throughout the organization incorporates risk in a transparent manner. This is in large part because of confidence in risk output because data and input is consistent with finance and actuarial analytics, models are validated and senior management and the board understand key assumptions and limitations.

The benefits

Realizing ERM’s promise requires more than just complex economic capital and value at risk (VAR) models. It requires confidence in these models and an understanding of their key assumptions and limitations. This confidence and understanding need to be pervasive – from risk, finance and actuarial personnel themselves, through line of business leadership, up to senior management and the board.

With a modernized platform in place, CROs and risk functions can turn their attention to managing risk, not calculating and reconciling numbers, as well as providing management and board with the best tools for intelligent decision making, confidence in capital deployment and competitive strategies consistent with risk appetite and capacity.

Critical success factors

Plan ahead and in concert with other stakeholders. The risk function is in the unique position of not having to dismantle infrastructure, but it definitely does need to build on it. The function’s relative youth and lack of legacy encumbrances mean it is in an ideal position to be a leader in modernization initiatives.

Moreover, the risk function has both an opportunity and an obligation to raise concerns about the risks involved in modernizing in an uncoordinated way or the risk to the insurer’s competitiveness from not modernizing at all.

Call to action – Next steps

Look for quick wins, like faster processing, more transparency, deeper insight, but stay true to the long-term plan. Some of these quick wins can be cost savings opportunities. For example, an inventory of documented models can reduce the number of models (and associated maintenance cost) by weeding out redundancies. In addition, the company can streamline internal reports when all areas use the same foundational data and calculations. Moreover, the company may be able to rationalize multi-jurisdictional, external and regulatory reporting.

A Hospital That Leads World on Transparency

Jeremy Hunt, secretary of state for health in Britain, recently toured the Virginia Mason Medical Center in Seattle. He said the visit was “inspirational” and announced plans to have the British National Health Service (NHS) sign up “heart and soul” to a similar culture of safety and transparency. Hunt wants doctors and nurses in NHS to “say sorry” for mistakes and improve openness among hospitals in disclosing safety events.

I had a similar reaction to my tour of Virginia Mason. The hospital appears impressive—and truly gets impressive results. My nonprofit, the Leapfrog Group, annually takes a cold, hard look at the hospital’s data and named Virginia Mason one of two “top hospitals of the decade” in 2010. Every year, it ranks near the top of our national ratings.

Virginia Mason’s success is rooted in its famous application of the principles of Japanese manufacturing to disrupt how it delivered care, partly at the behest of one of Seattle’s flagship employers, Boeing. There are numerous media stories and a book recounting the culture of innovation Virginia Mason deployed to achieve its great results, so I won’t belabor the point here. But at its essence is Virginia Mason’s unusual approach to transparency. Employees are encouraged to “stop the line” – that is, report when there’s a near miss or error. Just as Toyota assembly workers are encouraged to stop production if they spot an engineering or safety problem, Virginia Mason looks for every opportunity to publicly disclose and closely track performance.

It is not normal for a hospital to clamor for such transparency. Exhibit A: the Leapfrog Hospital Survey, my organization’s free, voluntary national survey that publicly reports performance by hospital on a variety of quality and safety indicators. More than half of U.S. hospitals refuse the invitation of their regional business community to participate in Leapfrog, suggesting that transparency isn’t at the top of their agenda. But for Virginia Mason and an elite group of other hospital systems, not only is the transparency of Leapfrog a welcome feature, but they challenge us to report even more data, faster.

I hope the British health care system takes Virginia Mason’s model and runs with it, but, more than that, I hope the model takes hold here in the U.S. Too many hospitals in the U.S. avoid disclosing their performance instead of welcoming transparency as an opportunity to build trust with the patients in their care.

The movement toward transparency has a long way to go. We do not have publicly disclosed accreditation reports, even though those reports are tickets for hospitals to obtain public funding through Medicare. We do not yet know enough about infection rates, sentinel events, medication errors and outcomes including death rates from many common (or uncommon) procedures. Price transparency is also rare, according to a report by the Catalyst for Payment Reform.

The ultimate example of our tendency toward non-disclosure came last week, when USA Today reported that CMS quietly removed from public disclosure the incidence of certain “never” events, like objects left in after surgery. Experts disagree on the merits of how CMS counts these “never” events, and CMS—no doubt influenced by lobbyists—believes that they aren’t fair to hospitals. Yet, in a culture of transparency, CMS would do the opposite: first err on the side of reporting the “never” events, then let the experts refine the measure over time. Indeed, as the Virginia Mason experience demonstrates, the very act of reporting can accelerate improvement and transformation.

It’s time for the U.S. to ignite its passion for free speech and lead the world in applying it to health care.