Simplifying insurance with plain language

Vol 47: Issue 2 | July 2024

In short

• Plain language uses wording, structure and design to make information easy to understand
  and use.
• In addition to enhancing the user experience and SEO, plain language can reduce customer enquiries and misunderstandings, saving insurers time and reducing the number of complaints.
• Rewriting insurance product disclosure statements in plain English can make customer and insurer responsibilities clearer, and helps to ensure you have genuine, informed consent when a customer purchases insurance.

In June 2022, communications firm Ethos CRS released a readability scorecard for 26 Australian insurance companies, reviewing their home and motor insurance product disclosure statements (PDSs), FAQs and websites.

The firm used a tool called VT Writer to measure average sentence length, passive and active voice and the grade reading level of the content.

On average, insurers scored 74 out of 100, with some scoring in the sixties and others — such as NRMA Insurance — achieving scores in the low eighties.

“Our team of accessible information specialists provides clear and concise information by including basic language and grammar, subheadings and simple font and layout, to help our customers understand the services and support we provide,” says an NRMA Insurance spokesperson.

“We have also enhanced the layout and content on our website to allow customers to find information more easily about our products and services, access our support and provide feedback about the accessibility of our services during their experience.”

So, what are some insurers doing right? And why does it matter?

What is plain language?

According to the International Plain Language Federation, “A communication is in plain language if its wording, structure and design are so clear that the intended readers can easily find what they need, understand what they find and use that information.”

Director of content at Ethos CRS Helen Portillo-Castro adds: “The focus is on the reader, and whether the reader can understand and use something. While we usually think of word choice when we think about plain language, there are actually three essential elements. Wording is just one of them.”

The other two are structure — the information you present and the order in which you present it — and design — fonts, colours, images and the like.

Over the past 85 years, the plain language movement has used brain scans, eye movement monitoring and user testing to confirm how important these last two elements are.

Says Greg Moriarty, product and quality manager at the Plain English Foundation: “If you want to put people off, use italics and all caps everywhere.

"Have tiered content in dot points 1.1.1 through to 1.4.6. To your customers, it looks like hard work — and the user testing is really clear that people will stop reading. It’s too much for the brain; they want an easy read.”

How plain language underpins UX

These elements of plain language should be ringing bells for anyone intimately involved with website content and design.

“Plain language was almost the original form of UX,” says Lynda Harris, founder and CEO of Write Limited and creator of the WriteMark® Plain Language Standard. “It is a cornerstone of usability, because users read or access information when they have to use it in some way — particularly insurance documents.”

Moriarty says that United States communications expert Ginny Redish draws an interesting distinction between paper documents and information on the web. “She says a paper document is a conversation started by the writer to the reader,” he explains. “Online, people look for what they want.

If they visit your website, that’s a business conversation the visitor started. You should continue having that conversation with the customer using the language they use.

“So many organisations treat their website like a library or a filing cabinet and whack up the documents they have. They should ask, ‘What question did the customer form in their head to generate the visit to this webpage?’.”

Flight-booking websites provide a good example of the effectiveness of this approach.

“Airlines realised that customers wanting to book a flight didn’t want to read a history of air travel,” says Moriarty. “They stripped everything back and now your flight booking form is at the top of the page.

"There’s no aviation jargon — just the departure date, destination, passengers and single or return trip. Seconds later, you’ve got a ticket to take you around the world.”

Building in the words and terms customers will use to find your website is a search engine optimisation (SEO) essential. And with voice search and artificial intelligence becoming mainstream, there’s an even bigger incentive to use natural language in place of industry jargon or legalese.

"Ask yourself, do you say: ‘Alexa, insurance claims process’ or do you say: ‘Alexa, how do I make an insurance claim?’.

Whenever you’ve done a plain-language rewrite, Harris recommends user testing, no matter how reader friendly you think the content is.

“You might have a webpage or document that is really quite clear to you, it reads well and it seems to tick all the boxes. But when you put it in front of real people who don’t have any particular understanding of insurance, that’s when you pick up those extra things that are still confusing,” she says.

Can insurance contracts be written in plain language?

A contract lies at the heart of any insurance product a customer purchases. So, can plain language capture all the legal nuances underwriters need to convey?

According to Harris, the risk-assessment role of an underwriter and a lawyer can lead to a more cautious approach. “Naturally they want to revert to wording that hasn’t got them into trouble in the past,” she says. “I think understanding why there is a reluctance [to change policy language] goes a long way to having a constructive conversation.”

In fact, some risk lies in not using plain language in insurance contracts.

Ethos CRS research officer Ethan Howard headed up the 2022 readability research. He says: “Mandated disclosures for insurance products are not enough for customers to make an informed financial choice. Using plain language is one element that can help insurers go beyond what is mandated.”

He says a number of regulators, including the Australian Prudential Regulation Authority (APRA) and the Australian Securities and Investments Commission (ASIC), are interested in the readability scorecard results and what they mean for consumers.

“Legal teams should be aware that using plain language is something that is mandated by the regulatory agencies themselves,” he says, “and I think there is a willingness among insurers to make the change.”

Using plain language can also clarify what actions are legal obligations for the customer and the insurer (‘you / we must’) and what actions are optional (‘you / we may’). Legal documents sometimes still use terms such as ‘should’, which can be open to interpretation by customers and the courts.

Contract structure and design can also play a big part in informed consent — particularly if you use sentence-like, descriptive headings and subheadings.

“If a customer looks at the start of a document such as a PDS, they should get a summary of what it says before they read the detail,” says Moriarty.

“They should be able to scan the subheadings and understand their main obligations. That’s a tentatively more ethical way to proceed when people are signing a contract.”

Advantages and efficiencies

Beyond creating a better user experience, using plain language can reduce customer enquiries and complaints, saving the company time and money.

No wonder, then, that industry codes of conduct, from New Zealand’s Fair Insurance Code to the Hong Kong Federation of Insurers’ Code of Conduct for Insurers and Australia’s Life Insurance Code of Practice, state that insurers must explain key information in plain language. (Notably, the revised Life Insurance Code was rewritten as a plain language document before its release in 2021 — a requirement of ASIC.)

“We know from the work that we’ve done over the last 20 or so years, how much organisational time gets lost in explaining and clarifying information that’s already there, on a website or in a document,” says Moriarty.

When it comes to reducing complaints, Howard points to the tangible benefits of clear communication. “Each year, AFCA [the Australian Financial Complaints Authority] summarises the information about the insurance complaints it receives.

These are the complaints that have gone beyond mediation, so they are significant problems for customers and insurers,” he says. “One of the leading complaints categories is denials of claims due to exclusions or conditions, or misleading product information. Using plain language is one way to avoid these issues.”

In fact, in AFCA’s 2023 annual review, denials of claims due to exclusions or conditions made up 17 per cent of general insurance complaints. Misleading product or service information was the most common issue in life insurance complaints, at 19 per cent.

Portillo-Castro notes that the UX concepts of ‘accessibility’ and ‘context’ are additional reasons to use plain language — whether for a customer who is a second-language English speaker or for someone who is a vulnerable customer.

“Plus, if someone has experienced a loss through a natural disaster, you need to consider their state of mind when they are dealing with their insurer,” she says. “They may be under a great deal of stress or experiencing mental health issues.”

Start small, but start now

Reworking all your webpages, PDSs and paper documents may appear daunting, but the SEO and UX benefits — and the efficiencies from reduced customer enquiries and complaints — more than justify the effort and investment.

In 2016, Tower became the first insurer in New Zealand to begin transitioning its policies to the WriteMark® Plain Language Standard. This involved updating policies, removing complex words and phrases, adding comparisons between different levels of cover, and new images and design features.

“The purpose was to make our policies easy to understand, giving customers confidence in what they’re covered for, without any surprises when it comes to claims time,” says Tower’s chief underwriting officer Ron Mudaliar.

To date, 80 per cent of the company’s policies in New Zealand and 70 per cent of policies in Fiji are WriteMark® certified — a practice Tower is pursuing with its policies in other Pacific territories.

“Our team has enjoyed reviewing our policies,” says Mudaliar. “Our customers are thrilled with the simplicity, and we’ve received lots of positive feedback in the years since first launching plain language policies.”

Harris says organisations are often hesitant about flagging their plans to address the issue of plain language until they’ve actually completed the work. “But really, customers appreciate the intention and commitment,” she says.

“Come out and tell your customer base that you’re going to do this. Start off with one thing and say, ‘We are so proud of our new terms and conditions’, or whatever it is. ‘We’ve made a real effort to get them in plain language.

"We’re on a journey and we’re really committed to this. We welcome your thoughts and your feedback’. Just be very open about it.

“You build the trust and the goodwill even before you act, and, as long as you follow through on that commitment, you can only do your reputation a great deal of good.” As Ernest Hemingway, a master of plain language, summed it up: “All you have to do is write one true sentence. Write the truest sentence that you know.”

7 basic principles of UX design

According to Dublin’s UX Design Institute, there are seven basic principles of UX (user experience) design:

1. User-centricity — solve user problems.
2. Consistency — meet user expectations, based on what they expect of the product.
3. Hierarchy — make the most important information easy to find.
4. Context — consider how users access and interact with your product and what their emotional and physical state is when they do.
5. User control — how simple it is to undo or redo actions and correct mistakes.
6. Accessibility — most users should be able to access and use your product.
7. Usability — how functional your product is.

Make some plain-language changes today

Plain language should:

• be clear and concise
• use everyday words instead of jargon or legalese
• explain technical terms in regular language
• keep sentences short (15–20 words)
• use the active voice
• use ‘you’ and ‘we’, rather than ‘supplier’, ‘customer’, ‘insured’ or ‘applicant’
• use sentence-like, descriptive headings and subheadings, such as ‘How to make a claim’ rather than ‘Claims process’
• use real-life examples and images to help bring concepts to life
• address the most common reasons customers visit a webpage first, going into more detail in deeper layers of the document or website.

To illustrate some simple wording differences, Tower offers the following before-and-after example.

Old policy wording:

The correctness of all statements made in relation to this policy or any claim under this policy is essential before we have any liability under this policy or pay your claim.

Plain language policy wording:

You must be honest and fair with us. All your statements about this policy and any claim must be honest, correct and complete.

Read this article and all the other articles from the latest issue of the Journal e-magazine.

Read issue 2 of the Journal