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 “improvements” were being implemented “to move Provident from a claim payment to claim management approach.” (Exhibit F, p. 125).  Ralph Mohney described the “keys to this transition” as “more intensive claim investigation” and “skill development to maximize effectiveness.” Id.  Mr. Mohney explained that even denying just a few claims would result in large increased profits for the company: “A 1% decrease in benefit costs due to more effective claims management translates to six million dollars in annual savings.  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.” (Exhibit F p. 125).

As part of the new training process, company employees were taught to avoid putting incriminating evidence in claim files.  A memo on “information management” 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.  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.

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