Exhibit D Page 1 of 6

EXHIBIT D, PERFORMANCE STANDARDS

A. The State expects the Contractor to perform at pre-determined levels of accuracy, timeliness, and administrative effectiveness. The quality and accuracy of Short Term Disability (STD) and Long

Term Disability (LTD) policy claim management and account management services will be assessed and measured according to the following performance standards.

B. The five separate claim management Performance Standards of Financial Accuracy, Data Entry, Coding Accuracy, Turnaround Time, and Benefits Center Responsiveness shall be reported by

Contractor to the State on a quarterly basis in electronic format within 45 business days after the end of the quarter, with a final monetary settlement by the Contractor to the State of Colorado annually, by October 31, for the previous plan year. For the performance reports that require quarterly reporting, Contractor shall also provide an additional roll-up report on an annual basis. Failure to meet the required delivery time for quarterly reports will result in a fine of $100 per day per report for every day any report is late.

C. The one separate account management Performance Standard of Account Management shall be reported by State of Colorado to Contractor on an annual basis in electronic format within 60 days after the end of the plan year, with a final monetary settlement by the Contractor to the State of

Colorado annually, by October 31, for the previous plan year. Failure to meet the required delivery time for annual reports will result in a fine of $100 per day per report for every day any report is late.

D. The period of time used to measure Contractor’s delivery of services in accordance with the

Performance Standards will be called an Audit Period.

a. Quarterly Reporting. The first quarter Audit Period will begin July 1, 2021, and will end

September 30, 2021. The second quarter Audit Period will begin October 1, 2021, and will end December 31, 2021. The third quarter Audit Period will begin January 1, 2022, and will end March 31, 2022. The fourth quarter Audit Period will begin April 1, 2022, and will end

June 30, 2022. Subsequent quarter Audit Periods will begin each July 1, October 1, January

1, and April 1.

b. Annual Reporting. The first annual Audit Period will begin July 1, 2021, and will end June

30, 2022. Subsequent annual Audits Periods will begin each July 1.

E. Contractor shall exercise its professional due diligence and judgment in assessing the Performance

Standards. Audits will be conducted based on the then current work processes in existence.

Notwithstanding the foregoing, no audit shall be performed and no penalty shall be payable on any

Performance Standard materially affected by a process, service or metric where Contractor and State of Colorado, by mutual consent during the term of this contract, have agreed to change the process, service or metric measured by such Performance Standard. In addition, any penalty otherwise payable will not be paid to State of Colorado until all premiums are paid in full according to the STD and LTD Policies in Exhibits G and H.

F. Any failure to meet the Performance Standards must be a result of factors under Contractor’s control.

A failure to meet Performance Standards due to factors beyond Contractor’s control will not be a failure to meet the Performance Standards.

DocuSign Envelope ID: 21AFD54E-9111-44ED-82E9-78BF332301BF

Exhibit D Page 2 of 6

G. Unless otherwise agreed by the Contractor and State of Colorado, if a penalty is due to State of

Colorado, Contractor will forward to State of Colorado a check in the amount of the penalty due.

State of Colorado will not withhold any premium due under STD Group Policy Number 419127 001 and LTD Group Policy Number 419127 002 based on its knowledge, expectation, opinion, or belief that a penalty is payable.

H. Financial Accuracy. Performance will be determined by auditing correctness of the liability determination, accuracy of the financial calculations, and accuracy of the disability duration. The following quarterly Performance Standards shall be computed separately for STD and LTD.

a. STD Financial Accuracy Performance Standard: At least 96% of STD claims will be calculated and paid in accordance with plan provisions.

b. STD Penalty: $5,000 per quarter; reported quarterly and assessed annually.

c. LTD Financial Accuracy Performance Standard: At least 96% of LTD claims will be calculated and paid in accordance with plan provisions.

d. LTD Penalty: $2,500 per quarter; reported quarterly and assessed annually.

I. Data Entry. Performance will be determined by dividing the number of audited claims processed within the Performance Standard by the total number of audited claims. The following quarterly

Performance Standards shall be computed separately for STD and LTD.

a. STD Data Entry Performance Standard: At least 90% of STD claims will be entered onto the claims administration system by the end of the business day following the date of receipt.

b. STD Penalty: $2,000 per quarter; reported quarterly and assessed annually.

c. LTD Data Entry Performance Standard: At least 90% of LTD claims will be entered onto the claims administration system by the end of the business day following the date of receipt.

d. LTD Penalty: $1,000 per quarter; reported quarterly and assessed annually.

J. Coding Accuracy. Performance will be determined by dividing the number of audited claim data elements processed within the Performance Standard by the total number of audited claim data elements. The following quarterly Performance Standards shall be computed separately for STD and

LTD.

a. STD Coding Accuracy Performance Standard: At least 90% of claimant data on claim payment/processing systems and in written communications will correctly reflect information provided to Contractor at the time of claim submission, and subsequently updated by the claimant, employer, treating provider or other relevant authority, in terms of:

i. Claimant Name

ii. Claimant Address

iii. Claimant Social Security Number

iv. Claimant Date of Birth

v. Disability Diagnosis Category

vi. Disability Date (Compensable Claims)

vii. Elimination Period

Note: Other relevant authority which may include, but not be limited to, claimant’s representative (e.g. attorney) or regulatory authorities.

b. STD Penalty: $1,500 per quarter; reported quarterly and assessed annually.

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c. LTD Coding Accuracy Performance Standard: At least 90% of claimant data on claim payment/processing systems and in written communications will correctly reflect information provided to Contractor at the time of claim submission, and subsequently updated by the claimant, employer, treating provider or other relevant authority, in terms of:

i. Claimant Name

ii. Claimant Address

iii. Claimant Social Security Number

iv. Claimant Date of Birth

v. Disability Diagnosis Category

vi. Disability Date (Compensable Claims)

vii. Elimination Period

Note: Other relevant authority which may include, but not be limited to, claimant’s representative (e.g. attorney) or regulatory authorities.

d. LTD Penalty: $750 per quarter; reported quarterly and assessed annually.

K. Turnaround Time. Performance will be determined by dividing the number of audited claims processed within the Performance Standard by the total number of audited claims. The following quarterly Performance Standards shall be computed separately for STD and LTD.

a. STD Turnaround Time Performance Standard: At least 95% of STD claims will reflect a determination to pay, pend or deny within 10 business days following receipt of a complete

STD claim. A STD claim is considered complete when Contractor has received all required employer, employee and attending physician information required to initiate claim processing.

b. STD Penalty: $5,000 per quarter; reported quarterly and assessed annually.

c. LTD Turnaround Time Performance Standard: At least 95% of LTD claims will reflect a determination to pay, pend or deny within the following timeframe:

i. For claims where Contractor does not provide STD coverage and/or claims administration services, within 45 calendar days following receipt of a complete LTD claim. A LTD claim is considered complete when the Contractor’s Disability Benefits

Specialist (DBS) has received all required information to make a determination.

ii. For claims where Contractor provides both the STD and LTD coverage and/or claims administration services, by the later of the first LTD benefit due date or within 45 calendar days following receipt of a complete LTD claim. A LTD claim is considered complete when the Contractor’s Disability Benefits Specialist (DBS) has received all required information to make a determination.

d. LTD Penalty: $2,500 per quarter; reported quarterly and assessed annually.

L. Benefits Center Responsiveness. Performance will be determined by dividing the number of audited claims contacts responded to within the Performance Standard by the total number of audited claims contacts received. The following quarterly Performance Standards shall be computed separately for STD and LTD.

a. STD Benefits Center Responsiveness Performance Standard: At least 90% of all claimant and employer contacts received by a Contractor’s Benefits Center representative will be responded to within the following timeframes:

i. Immediately or the same business day, for telephone calls received before 3:00 PM in the time zone of the Contractor facility called.

ii. Immediately or by the end of the next business day, for telephone calls received after

3:00 PM in the time zone of the Contractor facility called.

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iii. By mail or telephone within 5 business days from receipt, for written communications reasonably requiring a response.

b. STD Penalty: $1,500 per quarter; reported quarterly and assessed annually.

c. LTD Benefits Center Responsiveness Performance Standard: At least 90% of all claimant and employer contacts received by a Contractor’s Benefits Center representative will be responded to within the following timeframes:

i. Immediately or the same business day, for telephone calls received before 3:00 PM in the time zone of the Contractor facility called.

ii. Immediately or by the end of the next business day, for telephone calls received after

3:00 PM in the time zone of the Contractor facility called.

iii. By mail or telephone within 5 business days from receipt, for written communications reasonably requiring a response.

d. LTD Penalty: $750 per quarter; reported quarterly and assessed annually.

M. Account Management. The State of Colorado will evaluate the management of the account following the end of the year. The evaluation will include an assessment of the following factors:

understanding the State of Colorado’s business needs and service expectations; quality of services;

responsiveness; flexibility; seamless coordination; knowledge and professionalism; and employee perception. Performance will be determined by the State of Colorado’s scoring responses to the fourteen (14) categories of Contractor Account Management services in the assessment table below.

The following annual Performance Standards shall be computed separately for STD and LTD.

a. STD Account Management Performance Standard: A score of 3.75 or higher. State of

Colorado benefits personnel will be satisfied with the STD account management services delivered by the Contractor’s Account Team if the average score is 3.75 (out of a possible high score of 5) or higher as defined in the STD account management assessment table.

b. STD Penalty: $10,000 per year; reported annually and assessed annually.

c. LTD Account Management Performance Standard: A score of 3.75 or higher. State of

Colorado benefits personnel will be satisfied with the LTD account management services delivered by the Contractor’s Account Team if the average score is 3.75 (out of a possible high score of 5) or higher as defined in the LTD account management assessment table.

d. LTD Penalty: $5,000 per year; reported annually and assessed annually.

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