Workers Comp Code 9015 Building Or Property Management - All Other Employees

  • NCCI's #1 most reclassified code of 2017, work comp class code 9015 (Building Or Property Management - All Other Employees)

  • makes the NCCI list of most confusing codes every year.  It was #8 on the NCCI top 10 list in 2020 (below).

  • #5 Most Reclassified Workers Comp Code in 2021 (below)

Workers comp code 9015 Building Or Property Management - All Other Employees is a class code that should be reviewed if it is on your work comp policy.

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Work Comp Code 9015 could represent a significant cost-saving opportunity for you.

Some of the workers comp codes that are frequently misclassified should be in higher rated (more expensive) class codes.  In other words employers are coming out ahead and saving money. 

But, not class code 9015. It is frequently misclassified in the other direction; employers are overcharged

9015 Class Code most commonly misapplied in place of lower rated (less expensive) class codes.

According to the NCCI description of workers comp code 9015, it applies to the care, custody, and maintenance of premises or facilities.  Numerous activities and circumstances can influence the application of class code 9015.  For example:

 

  • Does the owner or lessee of a building occupy the entire or principal portion of the premises for manufacturing or mercantile purposes?
     

  • Is there maintenance or repair work at any location where the owner or lessee does not also perform janitorial services?

  • Do the property management employees work for a business whose governing class code is a Standard Exception classification such as Class Code 8810; Clerical Office Empolyees?

  • Is the ordinary maintenance and repair of a building performed by regular employees of the business?

  • Does the business employ painters, plumbers, electricians, carpenters, doormen, security desk personnel, elevator operators, gatekeepers, or concierges?

The 9015 Workers Comp Code Rate Is Significantly More Expensive

NCCI tells us that the workers comp code 9015 if one of the most reclassified codes in their Scopes Manual.  AND, when it is applied incorrectly it most is most commonly misapplied in place of classification code 9012.

Missouri publishes annually a list of the average rate* for every class code.  The difference between 9015 and 9012 is substantial.  In 2021 the average rate for workers comp code 9015 was $4.03 while the rate for classification code 9012 was $1.05; a difference of $2.98.  So, for every $100,000 in payroll misclassified as 9015 rather than 9012, employers are overcharged $2,980; 3% additional premium!

Here is a link to the Missouri rates for 2021.  This table is referred to as "self-insured rates."  In Missouri the Department of Insurance averages the rates charged by the top 20 insurance carriers and publishes them for work comp self-insurers.  Even though these employers self insure, they need to calculate what they would have paid were they purchasing their insurance in the voluntary market like you.  This is so taxes can be assessed and paid at the same rate for all employers.

NCCI workers comp code 9015 is on the list of most missclassified and, in turn, reclassified work comp class codes every year.  As stated above, it was the most reclassified code in 2017.  While it fell to the 8th most misclassified code between 2017 and 2020, it jumped again last year to #5, the 5th most misclassified workers comp class code.

 

Clearly, there is confusion over properly classifying builiding or property management firms.  And how to properly classify these business operations is not being communicated to auditors.

Class Code 9015 confusion can exist between it and other class codes

And, there's confusion in combination with multiple classifications.  Here are a few which are frequently considered alongside class code 9015:

  • Class Code 9012 – Building or Property Management

  • Class Code 9060 – Club—Country, Golf, Fishing or Yacht

  • Class Code 8855 – Banks and Trust Companies

  • Class Code 8723 – Insurance Companies

  • Class Code 9052 – Hotel

Workers comp code 9015, on the other hand, should be similarly applied from one state to another.  This helps.  NCCI's Scopes Manual (the dictionary for workers comp codes) has just one "Phraseology" for all states other than California.  So, no state exceptions for workers comp code 9015 which is great if you're a multi-state organization.  This work comp code should be applied uniformly across all your operations.   In other industries utilizing other codes state exceptions create much workers comp code confusion.

The rationale for the application of class code 9015 should be spelled out in Description Of Operations in your Auditor's Worksheets.  Any reclassification that occurs should similarly be explained in this document (as I stated on our 8810 web page).

 

Even if you have no dispute, it's a good idea to request and review these after your annual audit to examine all auditor notes about class code 9015.  And, FYI, your broker will not do this for you.  Even if a broker is a qualified payroll auditor (none are), your insurance company will not send your broker Auditor's Worksheets.  They will only send them to you due to the confidential nature of the payroll information contained.  You may then forward on to anyone whose consultation you engage, of course.

Even if your audit was a phone audit or completely performed using software, the auditor will (should) input class code 9015 explanations. You may find those in the miscellaneous notes section.

 

If you suspect your employees are misclassified or that your insurance carrier reclassified employees in error (be it class code 9015 or another), please consider allowing us to review your program to determine whether or not to initiate an audit dispute.  

 

Please call or email us to discuss your unique circumstances and potentially help your company, even for issues as old as 4 three years ago!.  These issues will continue to impact your work comp program and cost unnecessarily high premiums indefinitely.  So, let us know if you feel there are any issues related to class code 9015 that need an expert review.   We WILL help you!

Also, it would be a good idea to take a look at our warning signs and reach out if you'd like assistance for any other reason.  

Stuart Cytron

stuart@cytrongroup.com

LinkedIn

(314) 757-8079 t