Target Market Determination (TMD) – Flip Roaming

What’s a TMD?

A Target Market Determination or TMD is a document that describes which retail clients a product is likely to be appropriate for (aka the target market), and any rules around how the product can be distributed. It also describes the review and reporting processes we have in place, and reporting requirements that distributors need to follow.

This document isn’t a Product Disclosure Statement (PDS) or a summary of the terms and conditions or features of the product.  It doesn’t consider customers' personal objectives, financial situation or needs, who should head to getflip.com.au to learn more and read our PDS. 

This TMD relates to the Flip Roaming Accidental Injury Insurance PDS dated 28 November 2023 (Flip Roaming). In this document, ‘we’, ‘us’, ‘our’ and ‘HCF Life’ means HCF Life Insurance Company Pty Ltd, AFSL 236 806. HCF Life is the issuer of Flip Roaming. 

Key attributes

Scope of cover

Flip Roaming provides cover under a group life insurance policy issued to Flip Insurance Pty Ltd (Flip Insurance). Cover is distributed by Flip Insurance to customers, who can purchase cover, either for themselves or for their child (insured person), or for both. 

Flip Roaming pays a cash benefit if an insured person has an accidental injury at a covered overseas destination.  

Flip Roaming provides two types of benefits in relation to an accidental injury;  an Overseas Medical Refund benefit which pays the cost of reasonably necessary overseas medical care incurred by the  insured person up to A$20,000, plus an additional Extra Recovery Cash benefit ranging from A$100 to A$50,000 depending on the severity of the injury, up to A$50,000.  

Flip Roaming covers accidental injuries that happen in the following covered destinations:   Austria, Belgium, Bulgaria, Canada, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Fiji, Finland, France, Germany, Greece, Hungary, Indonesia, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland and the United Kingdom.    Australia and New Zealand are not covered destinations. 

An insured person can claim multiple benefits and/or accidents until they reach A$70,000 in total payouts. 

Cover can be: 

• purchased for a week or multiple weeks; and
• cancelled at any time, before cover starts. 

Eligibility criteria

An individual can purchase cover if they:

• are aged 18 to 64;
• living in Australia; and 
• have not received A$70,000 in payouts under Flip Roaming cover.

A parent or legal guardian can purchase cover on behalf of their child if:

• the child is aged 5 to 17; 
• both the parent or legal guardian and the child are living in Australia; and
• the child has not received A$70,000 in payouts under Flip Roaming cover.

Cost of the product

There is no underwriting for this product. The amount payable is A$80 for a week of cover.

Benefit limitations

• To be eligible for a benefit the insured person must:
  • suffer an accidental injury at a covered destination;
  • see a registered doctor within 14 days of the accident; and
  • either or both of:
     - receive overseas medical care within 6 months of the accident (for the Overseas Medical Refund benefit); and/or
     - have a registered doctor confirm that the accidental injury meets the required severity of injury within 6 months of the accident (for the Extra Recovery Cash benefit).
• A benefit is not payable for any accidental injury that happens because of:
  • motorcycling;
  • paid work or employment, unless the paid work or employment is a sport-related activity such as tennis coaching;
  • any accident outside the covered destinations;
  • something other than an accident, such as injuries that are sustained gradually through repetitive use over time e.g., tennis elbow;
  • taking illicit drugs or medication not as directed, or being under the influence of alcohol;
  • medical conditions, medical episodes, or by medical procedures or related complications;
  • intentionally causing self-injury or attempting suicide;
  • where the insured person is under 18, injuries caused by a parent or legal guardian or any person living with the insured person;
  • acts of war, whether declared or not, hostilities, civil commotion, terrorism or insurrection;
  • being involved in an illegal act; or
  • a dental injury caused by food or drink including any foreign object in the food or drink.

Other key attributes

This product does not cover:

• illnesses;
• travel related expenses; or 
• the cost of repatriation or transport back to Australia.

This is only a summary of key attributes, and it does not form part of the terms for this product. Please refer to the PDS for the terms and conditions for cover, including important definitions.

Target Market

Flip Roaming has been designed to be issued to Flip Insurance, for distribution to customers within the following target market:

Eligibility

If an individual is seeking cover for themselves, the individual must:

• be aged 18 to 64;
• be living in Australia; and 
• have not received A$70,000 in payouts under Flip Roaming cover.

If a parent or legal guardian is seeking cover on behalf of their child:

• the child must be aged 5 to 17; 
• both the parent or legal guardian and the child must be living in Australia; and
• have not received A$70,000 in payouts under Flip Roaming cover.

Objectives and needs

Customers in the target market will want and need cover that will:

• pay a cash benefit if the insured person experiences an accidental injury at one of the covered destinations during their chosen cover period;
• cover medical expenses incurred overseas associated with the accidental injury up to A$20,000; 
• provide additional supplementary financial support instead of cover for all or a percentage of other expenses associated with the injury; 
• run for a limited short-term period (weeks); and 
• involve a simple payment structure without underwriting.

Customers will not be in the target market if they: 

• want or need cover for:
  • accidental injuries from motorcycling;
  • the cost of repatriation or transport back to Australia; or
  • all costs associated with an accidental injury, such as unlimited medical cover or loss of income; or
• have or plan to obtain adequate travel or other insurance for accidental injuries at covered destinations.

Financial situation

Customers in the target market will have the financial capacity:

• to pay the premium; 
• to pay overseas health providers for medical expenses upfront before claiming a reimbursement from Flip; and
• to pay overseas health providers for any medical expenses that exceed the limit of cover or are otherwise not covered under Flip Roaming. 

Suitability of the target market

This product is likely to be consistent with the objectives, financial situation and needs of retail clients in the target market because:

• the group life insurance policy has been specifically designed to be issued to Flip Insurance;
• the target market includes customers whose objectives and needs are focused on cover that pays a cash benefit if the insured person suffers an accidental injury at one of the covered destinations.  Subject to only limited exceptions, Flip Roaming pays a cash benefit in similar circumstances, so it is likely to be consistent with the likely objectives and needs of retail clients who obtain cover; 
• the target market includes customers who have the financial capacity to pay up-front for medical expenses incurred overseas and to pay any expenses that are not covered.   Flip Roaming reimburses for medical expenses paid by the insured person, so it is likely to be consistent with their financial situation; and
• the target market includes customers who have the financial capacity to pay the premium, and the product requires payment of that premium in accordance with that chosen duration. If a customer has the financial capacity to pay the premium, then it is likely to be consistent with their financial situation.

Distribution conditions

Flip Roaming will be distributed solely by Flip Insurance. Flip Insurance must comply with the following requirements when engaging in retail product distribution conduct (distribution) in relation to Flip Roaming:

• Flip must ensure that all promotional and advertising material is consistent with the target market;
• cover can be obtained only through the website getflip.com.au, which must:
  • clearly and prominently explain key information about the scope, inclusions and exclusions of cover as part of the onboarding process; and
• the purchase process must include questions designed to determine whether the person comes within the target market, and the process must not permit cover to be provided in circumstances where that is not the case.

If cover is provided to a retail client in accordance with these distribution conditions, it is likely that the retail client would be in the target market. This is because:

• Flip Roaming has been specifically designed to be simple and easy to understand, with a fixed benefits and premium structure, no underwriting and limited exclusions; 
• cover can be obtained only through the website getflip.com.au, which is required to clearly explain key information about the cover as part of the onboarding process, permit cover to be issued only if the insured person comes within the target market, and require the customer to select a period of cover; and
• when considered in conjunction with the relatively simple terms for cover, this customer journey makes it likely that a customer would come to understand key information about the cover as part of the onboarding process. It also makes it likely that a customer would proceed with obtaining cover only if the cover would be consistent with their objectives, financial situation and needs. 

Reviewing this TMD and reporting obligations

We will review this TMD within one year of its effective date, and then every 2 years after the first review. We will also review this TMD earlier if any of the following review triggers occur, which reasonably suggest that the TMD is no longer appropriate: