NAD Recommends Trupanion, Inc. Discontinue Certain Claims for its Pet Medical Insurance and Modify Other Claims
New York, NY – Feb. 20, 2019 – Following a challenge by Nationwide Mutual Insurance Company, the National Advertising Division has recommended that Trupanion, Inc. discontinue certain advertising claims made for its Pet Medical Insurance and modify other claims. The challenged claims appear on Trupanion’s website and in emails, brochures, and other marketing materials.
NAD is an investigative unit of the advertising industry’s system of self-regulation and is administered by the Council of Better Business Bureaus.
Among the claims challenged, Nationwide took issue with Trupanion’s claims concerning Nationwide’s call center hours, its characterization of Nationwide’s Wellness Plans, Privacy Policy, coverage of certain conditions, its reimbursement policy under its benefits schedule plans, and its policy renewal exclusions. The vast majority of the challenged advertising consisted of express comparative claims regarding differences between Nationwide and Trupanion’s pet insurance policies—claims that Nationwide asserted were both false and disparaging.
The advertiser informed NAD that it had discontinued or modified portions of many of the challenged claims during the pendency of this inquiry. In all instances, the voluntarily discontinued or modified claims will be treated, for compliance purposes, as though NAD recommended their discontinuance or modification and the advertiser agreed to comply. NAD cautioned the advertiser that its changes to the challenged claims must be made consistently anywhere they appear, whether in print, online, email, etc., in order to be considered compliant.
NAD recommended that the advertiser’s claims concerning Nationwide’s call center hours (modified during the pendency of this proceeding) be further modified so that they are narrowly tailored to convey the message that a customer’s insurance policy coverage questions can only be answered during Nationwide’s customer call center hours and avoid conveying the broader message that Nationwide is unavailable at all outside of those hours (outside of call-center hours Nationwide offers a 24/7 veterinary helpline).
NAD recommended that the advertiser discontinue its claims regarding the Nationwide’s “Wellness Plans”—claims which NAD found to reasonably convey an overly broad message questioning whether wellness plans provide meaningful value, and the unsupported message that consumers that make use of Nationwide’s wellness programs do not receive a tangible benefit.
NAD determined that Trupanion’s claim—modified during the pendency of this proceeding to read—“VPI/Nationwide is a huge company with over 30 individual insurance products. They share policyholders’ private information to sell their other products, like car and home insurance” did not imply that the company shared private information with unaffiliated entities.
NAD recommended that the advertiser discontinue the claim that “Nationwide’s Major Medical Plan is the only plan available to puppies under one year of age.”
As for the coverage claims, NAD recommended the advertiser modify its advertising to make clear that the limitations on hereditary and congenital coverage discussed in its advertising only apply to one of the Nationwide’s products or discontinue the claim. NAD also recommended Trupanion modify its claim that Nationwide excludes “182 conditions” to accurately reflect typical consumer experience or discontinue this claim. NAD further determined that Trupanion’s proposed modification to one of its claims to read, “[i]n our view, excluding conditions based on breed is not fair. No pet deserves to be punished for being their specific breed.” did not falsely disparage Nationwide.
NAD recommended that the advertiser discontinue claims expressly stating or implying that Nationwide’s benefit schedule reflects what the company believes medical treatments should cost or how much veterinarians should charge consumers.
NAD recommended that the advertiser either discontinue the claim, “Conditions a pet develops over the past year that were covered by the VPI/Nationwide policy (or related conditions) can become excluded from coverage at annual renewal,” or modify it to expressly state, in the body of the claim (i.e. not in a link), that the claim refers to language in the Nationwide contract, not Nationwide’s practice.
NAD recommended that the advertiser discontinue the claims “VPl/Nationwide can cancel your policy with only 10 days’ notice for absolutely no reason at all” and “[t]hey can choose to not renew your coverage at your policy anniversary” or modify them so they are narrowly tailored to reflect the truthful claim that some of Nationwide’s contracts contain language that allows the company to cancel with no reason in a limited number of states.
Finally, the advertiser represented to NAD that it had permanently discontinued claims that Trupanion “has the highest payout rates in the industry,” “provides the most comprehensive coverage for accidents and illness in the market,” that Nationwide does not allow consumers to opt out of sharing of information, and that Nationwide excludes the “conditions pets are most likely to develop.”
In its advertiser’s statement, Trupanion agreed to comply with NAD’s recommendations and noted that it was Trupanion’s practice to carefully consider requested changes to advertising by competitors, and to make appropriate updates. Trupanion further stated that it supports the process of self-regulation and is adjusting its content to align with the NAD’s recommendations and, in fact, previously updated much of the challenged advertising based on information received from the challenger through these proceedings.
Note: A recommendation by NAD to modify or discontinue a claim is not a finding of wrongdoing and an advertiser’s voluntary discontinuance or modification of claims should not be construed as an admission of impropriety. It is the policy of NAD not to endorse any company, product, or service. Decisions finding that advertising claims have been substantiated should not be construed as endorsements.
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