Readability Workshop
 A Compliance Analyst’s Perspective
 History of Simplified Language
 How it’s Done
 State Requirements
 A State’s Perspective
 How to achieve the required score.
 How to handle nationwide forms
 The IIPRC’s Perspective
 IIPRC requirements
A COMPLIANCE ANALYST’S
PERSPECTIVE
 Rudolph Flesch
 Born in Vienna, Austria, studied law
 Fled to US during WWII, earned PhD in English
 1955 authored Why Johnny Can’t Read: And What You Can
Do About It.
 Supporter of the Plain English Movement.
 1979 authored How to Write in Plain English: A Book for
Lawyers and Consumers while working as a communication
and writing consultant to the FTC.
 Developed a formula for scoring the readability of written text
in 1948.
 J. Peter Kincaid
 Born 1942, is a scientist and educator
 Founding director of the Modeling and Simulation PhD
program at the University of Central Florida
 Both an educator and a scientist for the U.S. military.
 Developed the Flesch-Kincaid Readability Test for the US
Navy.
 Readability first used with the military to assess the difficulty of
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technical manuals.
Currently used on school text and by many US Government
Agencies
PA became the first state to require simplified language. 31 s
64.12 , adopted in 1975, requires a Flesch reading score of 40 on
automobile policies.
NAIC adopted the Life and Health Insurance Policy Language
Simplification Act Model 575 in 1977.
About 40 states have some type of regulatory requirements for
readability.
FLESCH READING EASE FORMULA
Scores can be interpreted as shown in the table below.
[8]
90‐100
80‐89
70‐79
60‐69
50‐59
30‐49
0‐29
Very Easy
Easy
Fairly Easy
Standard
Fairly Difficult
Difficult
Very Confusing
 Step 1. Count the words.
 Count as single words--contractions, hyphenated words,
abbreviations, figures, symbols and their combinations, e.g.,
wouldn't, full-length, TV, 17, &, $15, 7%.
 Step 2. Count the syllables.
 Count the syllables in words as they are pronounced.
 Count abbreviations, figures, symbols and their combinations
as one-syllable words.
 If a word has two accepted pronunciations, use the one with
fewer syllables. If in doubt, check a dictionary.
 Step 3. Count the sentences.
 Count as a sentence each full unit of speech marked off by a
period, colon, semicolon, dash, question mark or exclamation point.
Disregard paragraph breaks, colons, semicolons, dashes or initial
capitals within a sentence. For instance, count the following as a
single sentence:
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You qualify if(1) You are at least 58 years old; and
(2) Your total household income is under $5,000.
 Step 4. Figure the average number of syllables per word.
 Divide the number of syllables by the number of words.
 Step 5. Figure the average number of words per
sentence.
 Divide the number of words by the number of sentences.
 Step 6. Find your readability score.
 Input the average number of syllables and the average number
of words per sentence into the formula; or
 Find the average sentence length and word length of your
piece of writing on the chart. Take a straightedge and connect
the two figures. The intersection of the straightedge with the
center column shows your readability score.
 Some interesting scores
 Comics
 Consumer Ads in magazines
92
82
 Reader’s Digest magazine65
 Time magazine
 Wall Street Journal
 Harvard Law Review
 Standard Auto Policy
(prior to regulatory req.)
 Internal Revenue Code
52
43
32
10
-6 (yes, minus 6)
 Flesch–Kincaid Grade Level
 Translates the 0–100 score to a US grade level.
 The lowest grade level score in theory is 3.40,
 However, Green Eggs and Ham by Dr. Seuss scores a grade level
of 1.3. (Most of the 50 used words are monosyllabic; "anywhere", which occurs 8
times, is the only exception.)
 About 40 states have readability requirements.
 Many follow the NAIC model.
 Most require a score of at least 40
 Some require a higher score for certain products like Medicare
Supplement
 NAIC Model 575—Life and Health Insurance Policy
Language Simplification Act
 Adopted in 1977
 Does not apply to:
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Any policy which is a security subject to federal jurisdiction.
Any group policy covering a group of 1,000 or more lives at issue,
other than group credit life or group credit health. However,
certificates must comply.
Any group annuity used as a funding vehicle for pension, profit
sharing or deferred comp plans.
 NAIC Model 575
 Requires a minimum Flesch score of 40. Other comparable
tests can be used
 Forms must be printed in at least 10 point type
 Style, arrangement and overall appearance give no undue
prominence to any portion of the text
 Policy contains a table of contents if the policy has more the
3,000 words printed on 3 pages, or printed on more than 3
pages regardless of number of words
 NAIC Model 575
 Policy forms with 10,000 words or less, the entire form must
be analyzed.
 Policy form with more than 10,000 words, can choose two 200
word samples to analyze.
 Riders, endorsements, applications and other forms made a
part of the policy may be scored as separate forms or as part
of the policy.
 NAIC Model 575
 Text that can be excluded
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Name and address of the insurer
Name, number or title of the policy
Table of contents or index
Captions and sub-captions
Specification pages, schedules or tables
Language drafted to conform to the requirements of any federal law,
regulation or agency interpretation
Language required by any collectively bargained agreement
Medical terminology
Words which are defined in the policy
Language required by law or regulation
 NAIC Model 575
 The commissioner, at his/her sole discretion, may authorize a
lower score if he/she finds a lower score:
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Will provide a more accurate reflection of the readability of a policy
form
Is warranted by the nature of a particular policy form or type or
class of forms; or
Is caused by certain policy language which is drafted to conform to
the requirements of any state law, regulation or agency
interpretation.
A STATE’S PERSPECTIVE
 Use monosyllabic words wherever possible.
 Keep sentences short.
 Punctuate bulleted lists with periods, not semicolons.
 Use numerals rather than spelling out numbers.
 Where possible, score more challenging documents
(such as applications or short endorsements) in
conjunction with longer documents (the base
coverage).
 Use the statute or regulation to your advantage.
 Every policy should be understandable to consumers.
 When crafting a form, keep the “benchmark” limits in
mind (currently, the highest score required is 50 on the
Flesch scale).
 If the upper limit is met on the initial filing, no further action
is required.
 There are some state requirements that may be
contradictory, making it impossible to meet those
requirements on a national level. This is not one of those
situations.
 While most states have a minimum score requirement,
none have a maximum.
If a readability objection is received from a state, please
proceed appropriately.
 Look carefully at the objection for mitigating options.
 Before committing to rewriting a form, see if the form can
be rescored in context.
 If a form does need to be rewritten, make sure that those
who participate in the process understand the readability
requirements that need to be achieved.
 Once you have received a few objections regarding readability,
make sure future filings meet the readability requirements.
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Do not do anything that might make a regulator decide that
double checking the stated score is a good idea.
 Simply changing the score without editing the form or
explaining any change in context would raise red flags.
 So would “odd” math - if a form that scored in the 20s is
scored with a form that scored 50.0 and they both now
show a score of 63.5, the regulator might try to get to the
bottom of that mystery.
THE IIPRC PERSPECTIVE
Adopted by the IIPRC
Appendix A
Flesch Methodology
The following measuring method shall be used in determining the Flesch score:
(1) For forms containing 10,000 words or less of text, the entire form shall be analyzed. For
forms containing more than 10,000 words, the readability of two, 200-word samples per
page may be analyzed instead of the entire form. The sample shall be separated by at
least 20 printed lines.
(2) The number of words and sentences in the text shall be counted and the total number of
words divided by the total number of sentences. The figure obtained shall be multiplied by
a factor of 1.015.
(3) The total number of syllables shall be counted and divided by the total number of words.
The figure obtained shall be multiplied by a factor of 84.6.
(4) The sum of the figures computed under (2) and (3) subtracted from 206.835 equals the
Flesch reading ease score for the policy form.
(5)
For purposes of (2), (3), and (4), the following procedures shall be used:
(a)
A contraction, hyphenated word, or numbers and letters, when separated by spaces,
shall be counted as one word;
(b)
A unit of words ending with a period, semicolon, or colon, but excluding headings and
captions, shall be counted as a sentence; and
(c)
A syllable means a unit of spoken language consisting of one or more letters of a
word as divided by an accepted dictionary. Where the dictionary shows two or more
equally acceptable pronunciations of a word, the pronunciation containing fewer
syllables may be used.
(6) The term “text” as used in this section shall include all printed matter except the following:
(a) The name and address of the insurance company; the name, number or title of the
policy or certificate; the table of contents or index; captions and sub-captions;
specifications pages, schedules or tables; and;
(b) Any language which is drafted to conform to the requirements of any federal law or
regulation; any language required by any collectively bargained agreement; any
medical terminology; any words which are defined; and any language required by law
or regulation; provided, however, the insurance company identifies the language or
terminology excepted by this paragraph and certifies, in writing, that the language or
terminology is entitled to be excepted by this paragraph.
(7) At the option of the insurance company, riders, endorsements, amendments, applications
and other forms made a part of the policy or certificate may be scored as separate forms
or as part of the policy or certificate with which they may be used.
QUESTIONS?