Who Writes the Buckets Decides the 44%: APCIA's Plan to Standardize "Closed Without Payment"

On November 2, the board chair of the trade group that speaks for property and casualty carriers told its annual meeting that the industry has no consistent definitions or standardized coding for claims that close without payment, and that the group is building a template to fix that.² A month earlier, two senators had attached a number to the problem: the five largest home insurers did not pay on over 44% of claims resolved in 2025, up from 36% a decade before.¹

What the senators asked, and what the release leaves out

Sens. Elizabeth Warren and Josh Hawley sent letters dated October 2 to State Farm, Allstate, USAA, Farmers, Liberty Mutual and American Family, with responses due October 16.¹ The release links to a signed PDF for each carrier. The release text itself asks about claims-handling tactics and record profits, and it never says how a claim "closed without payment" gets defined or coded. The letters may, and they were not opened for this post.¹ The release also cites premiums up 70% nationally from 2019 to 2025 and a 2024 Insurance Information Institute study finding that 12% of Americans no longer had home insurance, up from 5% in 2019, so the senators framed the closure rate as one piece of an affordability problem.¹

Bell described the pressure on insurers as a "horseshoe effect" of populism from both ends of the spectrum, and said it on the eve of the midterm elections.² The letters themselves came from Warren, a Democrat, and Hawley, a Republican.¹ Whatever the politics, the carriers' answers to the October 16 deadline are the next documents that could show how each company codes a closure, and the release does not say whether they will be made public.

APCIA's board chair, David Bell, who is also president and CEO of ALPS Corp., answered at the association's Boston meeting. Insurance Journal reports that he said claims close without payment for reasons other than coverage denial, that members should acknowledge when companies fall short, and that the template is meant to give the industry accurate facts to answer criticism.² The article reports nothing on the template's scope, timeline, definitions, or any role for the NAIC.²

Triple-I made the same argument in June, before the senators wrote. Its statement lists four reasons a claim can close with nothing paid (damage under the deductible, a loss the policy does not cover, a duplicate submission, and an investigation that finds nothing owed) and says claims closed without payment "are not synonymous with denied claims."³ It adds that insurers count claims differently and that one loss can carry several exposures, some paid and some not.³

Three forms, three ways to split one bucket

Regulators already collect this number, and they do not collect it the same way. The NAIC's Market Conduct Annual Statement for homeowners, in its 2017 data-year version, has two closed-claim counts: closed with payment and closed without payment, with below-deductible claims assigned to the second.⁴ The same document defines a claim as a request for payment that may fall within coverage and excludes information-only events and coverage inquiries that never became a claim.⁴ It defines no finer category such as withdrawn, duplicate, or denied.⁴

Florida's catastrophe data call after Hurricane Isaias splits the same bucket five ways.⁵ The matrix lays the three side by side. Read each column as what that source names, since none of the three says how a given carrier codes a given closure.

Row four is the one that moves the headline. Under the MCAS definition an inquiry that never matured into a claim is not counted at all. Under Florida's footnote the same event, "insured inquiry only," sits inside claims closed without payment.⁴⁵ One taxonomy shrinks the denominator before the percentage is computed, and the other keeps it in.

What the Florida split shows

Florida's Isaias page, with data as of October 27, shows 24,635 closed claims, 9,293 of them with payment and 15,342 without, which is 62.3% closed without payment.⁵ The same page a week earlier read 70.3%, as the earlier Isaias post reported.⁶ No definition changed in between, which fits payments catching up with closures already counted.

Administrative reasons carries 9,837 of the 15,342, with below-deductible closures at 4,040, other exclusions or no policy in force at 1,242, no flood coverage at 220, and fraud at three.⁵ OIR's footnote says administrative reasons may include an inquiry only, a claim the insured withdrew, a duplicate or mistaken opening, an incorrect date of loss, or a lack of cooperation or communication.⁵ Three of those are housekeeping. The last one is a finding about the insured's conduct, and it sits in the same bucket as a duplicate entry.

Run the arithmetic on those counts and the dispute narrows to one question. Exclusions, no flood coverage, no policy in force and fraud total 1,465, which is 9.5% of the closures without payment and 5.9% of all closed claims. Below-deductible and administrative closures make up the other 13,877, or 90.5% of the category.⁵ Bell's point that claims close for reasons other than denial has support in that split. The senators' question about delay tactics lives inside the administrative line, where a lack-of-cooperation finding sits next to a duplicate entry, and no public data separates them. A template that gave lack of cooperation its own code would let both sides test their positions. One that left it inside administrative reasons would let both keep them.

The two Isaias readings also show that a closed-without-payment rate carries a date. Seven days moved Florida's figure by eight points on identical definitions, so a pitch deck, a client letter or a complaint that quotes a rate should quote the as-of date beside it.⁵⁶

Who controls the coding controls the 44%

A standardized template has to settle several questions, and each moves the number in a direction a public adjuster can predict.

Below-deductible closures are the first. The MCAS counts them as closed without payment, and Triple-I lists them as a reason, so a template that keeps them leaves them in the numerator, while one that separates them lets the industry report a lower figure for claims closed on coverage grounds.³⁴ Whether inquiries and withdrawals count as claims at all is the second choice, and the MCAS and Florida answer it differently, as the matrix shows.⁴⁵ The third is how to count a loss with several exposures, a point Triple-I raised itself.³

A public adjuster's pitch leans on the 44% more than on any other figure, and the figure belongs to the Journal's analysis as the senators restated it. Triple-I's warning applies to the pitch as much as to the press: a closed-without-payment rate describes how files ended, and a denial rate describes why.³ Pitching the first as the second hands a carrier the rebuttal it already wrote.

Reading your own closures against the buckets

The practical use is on open and recent files. For every claim or exposure a carrier closed without payment, write down which reason the carrier gave and which bucket that reason would land in under each form above. A below-deductible closure is arithmetic you can check against the declarations page and the estimate. A "lack of cooperation" closure is a handling finding, and a dated log of calls, emails and certified-mail receipts is the rebuttal. A duplicate or opened-in-error closure often means a supplement or second exposure was folded into the first file, which is worth confirming before the file goes quiet.

A firm with a few hundred closed files can build its own version in an afternoon: one row per closure, one column for the carrier's stated reason, one for the bucket. The result will not match the Journal's figure and is not meant to. It shows what share of the firm's closures were below deductible, what share were administrative, and what share rested on a coverage position, which is the split a carrier data call is about to standardize and the one a client can act on.

Ask the adjuster of record for the closure reason in writing and keep the answer in the claim log. When APCIA's template is published, the file that already carries a written reason can be sorted into whatever categories it uses without reconstruction. The related Texas problem, written denials that are never sent, is covered in TDI's memo on written claim denials, and the broader practice of documenting each carrier decision is laid out for public adjusters.

What is not known yet

No APCIA document was found. Bell's remarks are sourced here only to Insurance Journal's reporting, and nothing in this post attributes a quote to an association release.² The template's scope, timing, participating states and any NAIC role are unknown. The 44% and 45% figures were checked against the Senate release and not against the Journal's methodology, which sits behind a paywall.¹ The MCAS elements cited are from the 2017 data year, and a later reporting blank may define more categories.⁴ The template itself, any published carrier responses to the senators, and whatever the NAIC does with closure coding would settle most of this. Until one appears, treat every closed-without-payment percentage as a number whose bucket rules are unstated. Florida's data covers one storm, and its five-way split says nothing about how any single carrier codes a closure.⁵