Provident Unfair Practices Memo

An example of the unfair practices is evident in a 1995 memo between Provident executives Ralph Mohney and Harold Chandler states that a number of โ€œimprovementsโ€ were being implemented โ€œto move Provident from a claim payment to claim management approach.โ€ (Exhibit F, p. 125). ย Ralph Mohney described the โ€œkeys to this transitionโ€ as โ€œmore intensive claim investigationโ€ and โ€œskill development to maximize effectiveness.โ€ Id.ย  Mr. Mohney explained that even denying just a few claims would result in large increased profits for the company: โ€œA 1% decrease in benefit costs due to more effective claims management translates to six million dollars in annual savings. ย We believe that aggregate improvement in the 5-10% ($30 million to $60 million dollars annually) range are possible-once the initiatives have been fully implemented.โ€ (Exhibit F p. 125).

As part of the new training process, company employees were taught to avoid putting incriminating evidence in claim files. ย A memo on โ€œinformation managementโ€ from the Provident Law Department instructs employees to:

–Think before you speak or write. . . .

–[ask yourself] by disclosing it, am I putting the Company at risk legally or financially

— for matters that are especially sensitive or confidential, consider conducting most of you[r] communication in person, no[t] on paper. . . .

–Shred all sensitive papers that will not be needed for business purposes. ย Generally, when copies of certain legal type documents are sent to you for informational purposes only, these documents should be shredded after you have read them. . . .

–when finished with a project, destroy temporary drafts, reminder notes, worksheets, personal memos. . .

(Exhibit F, p 164-66)

**It should be noted that these unfair practices are alleged and/or reported occurrences dating back to the 1990’s as part of Provident’s history as a company and in no way should be misconstrued to be an accusation that these practices are still being performed.