Gisc welcomes the generally helpful coverage by Richard Brewster ("Getting up to scratch", Insurance Times, September 13) to the General Insurance Standards Council (GISC) Competence and Training requirements. May I, however, address the three specific issues labelled in the article as "intermediary worries".

First, on the question of whether members have to achieve "compliance with all the rules from day one" I would refer readers to our website's ( frequently asked questions - rules (general, question 5), where it states: "Members will be expected to be proactive in analysing the application of the rules to their own businesses and implementing any necessary changes. There is also, on the part of some applicants, particularly those who are familiar with regulatory oversight, nervousness that a failure to demonstrate full compliance from day one will risk an immediate adverse response from us. We have said publicly that applicants who feel they may not be fully compliant with the rules should not delay their applications, but contact us to discuss areas of doubt with a view to achieving full compliance at the earliest practical date."

Second, on the question of whether our monitors "are sufficiently familiar with the business to give a fair and informed view", I would reassure readers that both Price-waterhouseCoopers and Ernst & Young are providers of professional services. They have been contracted to the GISC through their insurance practices and the GISC is determined to ensure their staff conducting monitoring visits to GISC members and their appointed agents are suitably experienced.

Third, the GISC is committed to its regulatory framework delivering the level playing field sought by the industry and is also determined that the accreditation of members' training programmes is not a means whereby "direct writers and major connections, such as building societies, will avoid the sort of monitoring and investigation to which intermediaries will be subjected". Accreditation is available to all members and the cost of accreditation will be commensurate with the extent of the programme under review. Indeed, interest in accreditation has been expressed as much by smaller intermediaries as by larger GISC members.

In addition, we will accredit third-party training programmes, some of which are likely to be designed for smaller practitioners and for non-insurance specialists, offering another option to members who may not be able to develop their own programmes.

I would also like to address two other points raised in the article. With regard to monitors wanting "to ensure staff have a wider understanding than that which enables them to complete the job in hand", this is most definitely not the case. The GISC's Rules on Competence and Training clearly state that members' employees who act in a general insurance activity-related capacity must have adequate knowledge and skills for the requirements of their job. The rules do not require that members exceed this level of competence. In our Competence and Training Guidance we further explain that "the level of competence, depth of knowledge and range of skills will depend upon the nature of the role and responsibilities of the employee, the class(es) of business the employee is engaged in and the types of customers with whom they deal".

Finally, Brewster is correct in identifying that documentary evidence of employees' training needs, and training undertaken, is a key constituent of compliance. We would expect many members already have training and development programmes in place to ensure employees are competent to carry out their roles - but the definition and assessment of competence for these roles may simply not be formally recorded.

Again, our Competence and Training Guidance document has examples of records that members may wish to apply or adapt and I believe that the consultative approach taken by our monitors assists significantly in identifying and implementing improvements.
Angela Darling
Head of policy

Not my point
Lewis Rudge's letter ("The ATE answer", Insurance Times, October 11) attributes to me a view which is completely opposed to the one I was seeking to express. I was advocating, in fact, that insurers should provide, as a standard policy feature, access to uninsured loss recovery (ULR) facilities through an independent supplier, not that they should undertake the cover themselves.

I agree totally with Rudge that to do that would be unacceptable and I would never argue otherwise. In fact, my own company, CIS, uses DAS to provide this support to our policyholders at no cost to the customer."
Duncan Bowker
Co-operative Insurance Society

Patient partnership
The article by Paul Stanley ("Time to get into rehab", Insurance Times, August 30) has been brought to my attention. We welcome the increasing profile given to rehabilitation in improving the care of patients post-injury in this feature, but wish to correct a number of points, which could mislead your readers.

Physiotherapy as a profession is not concerned simply with doing things to patients. Individual patients are assessed to establish their needs and a programme of care. While this might include active intervention, such as manual therapy, this does not occur in isolation. This forms part of a package of care, which includes education and exercise, designed at promoting recovery in the first instance and then future maintenance and the prevention of problems. In taking this approach, patients are empowered to take action themselves. While this is highlighted in the article, it suggests that it is not the domain of physiotherapy and a new approach, when in actual fact it is a core component of what we do.

The Quebec Task Force study on whiplash quoted in the article acknowledges that mobilisation therapy plus home exercises is better than rest. The evidence for many other interventions was inconclusive, which should not be read to imply that they are ineffective. We need more high-quality research to inform many areas of practice.

We hope this reassures your readers that physiotherapists are already working in partnership with patients to improve rehabilitation.
Tracy Bury
Head of research and development
Reseach and Clinical Effectiveness Unit
The Chartered Society of Physiotherapy

Riding out the storms
Kim Bullimore's letter of the week ("Why not outsource underwriting?", Insurance Times, October 11) highlights one of the fundamental problems in our business.

Underwriting is a core competency for an insurer and so, in my view, is the handling of claims. There may be times when giving the pen to others works, but for much of the commercial insurance market, I really cannot see the point of existing as an insurer if it is not to underwrite.

The general standard of good old-fashioned training has fallen miserably and, in some companies, will be at danger levels. It's not just about understanding policy wordings, it's about understanding risk and developing commercial nous - that's our business.

Earlier this year we launched our Underwriting Academy in close liaison with the Chartered Insurance Institute (CII), because some time ago we decided to become an underwriting-led insurer - nothing new.

But this way we will ride out the storms that will inevitably come.

The insurers that fail to grasp this will see their bottom lines crumble away.
Bob Eveleigh
Commercial lines executive
Allianz Cornhill