Exclusions & Conditions

Verifiable Source: How Pet Insurers Decide Pre-Existing

Updated May 20266 min readNAIC Model Act §3

A verifiable source is the single piece of NAIC vocabulary that decides whether a pet insurer can call a condition pre-existing — and whether your appeal of a denial has legs. SOAP notes count. Lab results count. The intake form your vet tech filled out from your verbal recollection does not. This page covers what qualifies, what doesn't, and the exact written language to use when appealing a denial that doesn't cite one.

The 30-second answer

NAIC §3 forbids insurers from denying a claim as pre-existing without a verifiable source — signed vet records, SOAP notes, lab results, imaging reports, or pharmacy histories. Owner statements, intake forms, and breeder paperwork don't qualify. If a denial doesn't cite a verifiable source by name and date, you can appeal it in writing and win.

What counts as a verifiable source

NAIC Model Act §3 defines a verifiable source as documentation that is dated, attributed to a licensed professional, and tied to your specific pet. Insurers across the U.S. follow a fairly consistent list of what they will and won't accept:

Document	Verifiable?	Why
SOAP-format exam notes	Yes	Signed by DVM, dated, patient-specific
Lab results (CBC, chem panel)	Yes	Lab-of-record, dated, patient ID
Imaging reports (rads, US, MRI)	Yes	Read by licensed radiologist or DVM
Histopathology / biopsy reports	Yes	Pathologist-signed, dated
Pharmacy / prescription history	Yes	From licensed pharmacy, patient-tied
Owner intake form (handwritten)	No	Owner-completed, no DVM attestation
Breeder paperwork	No	Not from licensed veterinary professional
Phone-call notes from vet tech	No	No DVM signature, often undated

How insurers actually use verifiable sources

When a claim is filed, the insurer's claims adjudicator pulls every record that pertains to the body system or condition involved. For a torn cruciate, that means every musculoskeletal exam, every limp note, every gait observation in the file going back to enrollment — and often back to the pet's first vet visit. The adjudicator looks for any documented mention of the condition or its precursor signs before the effective date or during the waiting period.

If they find one — "mild stiffness in left rear, recheck in 30 days" signed by Dr. Smith on a date prior to enrollment — the claim is denied as pre-existing. If they don't find one, the claim should pay. The denial letter must name the document, the date, and the clinician. A denial that says "based on the medical history we received" without specifics is not compliant with §3 and is the easiest type to overturn on appeal.

How to appeal a denial that doesn't cite a verifiable source

Request the source document in writing. Email or fax: "Per NAIC Model Act §3, please provide the verifiable source — including document name, date, and signing clinician — used to determine pre-existing status." The insurer must respond within 30 days at most carriers.
Pull your own complete record set. Email a records-release request to every vet your pet has seen. Most clinics deliver within 5–10 business days. Save PDFs locally.
Read the cited document carefully. Many denials cite a record that mentions a different body system, a different condition, or notes a clean exam — none of which support pre-existing. Highlight the inconsistency.
If no source is provided, file a formal appeal. State that the insurer has not produced a verifiable source per NAIC §3 and request the claim be reopened. Attach your record set as supporting evidence.
Escalate to the state DOI if denied a second time. Florida (and 30+ other states) have adopted §3 and will investigate carrier compliance. Most state-level escalations are resolved before formal hearing.

Florida-specific note

Florida adopted NAIC Model Act §633 in 2023, codified within Chapter 627 of the Florida Statutes. The verifiable-source standard is enforceable through the Florida Office of Insurance Regulation (FLOIR), and a denial that doesn't cite a verifiable source can be reported via FLOIR's consumer complaint portal. As an FL-licensed agency, Wrisor walks customers through the appeal language at the time of denial — most carriers reverse non-compliant denials before formal escalation.

Get covered before the records become history

The verifiable-source rule protects you only when the records existing today are clean. Enroll while they are.

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Frequently Asked Questions

Verifiable source is the NAIC Model Act §3 term for the documented evidence an insurer is allowed to use when deciding whether a condition is pre-existing. It includes signed vet exam records, SOAP notes, diagnostic imaging reports, lab work, and pharmacy histories. Owner statements, breeder statements, and verbal recollections are not verifiable sources and cannot be used to deny a claim by themselves.

Under NAIC §3, an insurer cannot deny a claim as pre-existing without a verifiable source documenting the condition before the effective date or during the waiting period. If the only evidence is a hand-written intake form or a phone call, the denial is appealable. This single rule shifts the burden of proof onto the insurer and is the basis of most successful pre-existing appeals.

SOAP-format exam notes, written vet records signed by a licensed DVM, lab results (CBC, chemistry, urinalysis), imaging reports (radiographs, ultrasound, MRI), histopathology reports, prescription histories from a licensed pharmacy, and specialist referral letters. Records must be legible, dated, and tied to a specific patient — illegible scans and undated entries are routinely rejected on appeal.

Owner-completed intake forms, breeder paperwork, microchip registration data, social-media photos, phone-call notes from a vet tech, and undocumented "verbal histories." These can prompt an insurer to request more records, but cannot stand alone as the basis for a denial. If a denial cites only one of these, you have grounds to appeal.

Federal regulations do not give pet owners the same record-access rights as human HIPAA, but every state board of veterinary medicine requires vets to release patient records on written owner request. Email or fax a signed records-release request to every vet your pet has seen. Most clinics deliver within 5–10 business days. Save PDFs locally before any policy decision.

Insurers can request records directly from your vet under a HIPAA-style authorization in your application. They cannot pull records you did not authorize. If a denial cites a clinic you never disclosed, request the source document from the insurer in writing — under NAIC §3 they must provide it within 30 days, and any denial without one is appealable.

Yes — and these appeals win frequently. Submit a written appeal stating the insurer has not produced a verifiable source per NAIC §3, attach your own record set, and request a written explanation citing the specific document used. NAPHIA member carriers (the majority of the U.S. market) commit to this standard. Many denials are rescinded once the burden of proof is challenged formally.

Sources

NAIC Pet Insurance Model Act #633 (2022) — §3 verifiable-source definition and denial standards
NAPHIA 2024 State of the Industry — claims appeal volumes and resolution rates across NAPHIA member carriers