He said the company had failed to sell to the emerging individual health insurance market as effectively as possible because the company had not established a direct-response discipline and infrastructure to measure the success of direct marketing campaigns.

He said that the company needed to establish a disciplined and sustainable approach to direct marketing that would give the company the ability to...

• establish an ongoing, control-based creative testing program to ensure that the most successful, response-generating creative is in the market
• predict which segments are most likely to respond and convert
• track and measure individual campaign performance in real time