Your Client Names the Employer. Now What?
A new DBA claimant walks into your office. They worked for a military logistics contractor in Afghanistan from 2014 to 2017. They know their employer's name. They might have a supervisor's name. They have no idea who carried the DBA insurance policy.
You could file a FOIA request with the Department of Labor and wait months. You could call the employer directly and hope someone in HR remembers a policy number from eight years ago. Or you could look for the one document that was designed to answer exactly this question: the OWCP coverage card.
Coverage cards, formally known as LS-570 filings, are proof-of-insurance documents that DBA-authorized carriers file with the Department of Labor's Office of Workers' Compensation Programs. Each card links a specific carrier to a specific employer for a defined coverage period. They are the bureaucratic receipts of the DBA insurance system, and for attorneys tracing carrier responsibility, they are the single most direct evidence available.
But coverage cards are not a magic bullet. They expire. Employers change names. Carriers file late or skip filings entirely. The gap between what coverage cards should tell you and what they actually tell you is where most DBA investigations stall. This article breaks down what LS-570 filings contain, why they matter, and what to do when the paper trail goes cold.
What Does an OWCP Coverage Card Actually Contain?
An LS-570 filing captures five critical data points. The carrier name identifies which authorized DBA insurer filed the card. The employer name shows which company the policy covers. The policy number ties the filing to a specific insurance contract. And the effective dates mark the start and end of coverage.
That combination of fields creates what attorneys need most: a direct, dated link between an employer and its DBA carrier. Unlike case summaries that show aggregate claim counts, or OALJ decisions that mention carriers only in the context of disputed claims, coverage cards exist solely to document who insures whom and when.
The DOL has maintained these records since the 1940s. Pre-2012 filings were physical index cards kept in district office filing cabinets. Post-2012, the DOL transitioned to a digital tracking system, though structured external access remains limited. That 78-year span means coverage cards can reveal carrier relationships that no other source preserves, including carriers that have since merged, been acquired, or exited the DBA market entirely.
For practitioners working through a systematic carrier identification process, coverage cards sit at the top of the evidence hierarchy. A valid LS-570 filing from the relevant time period is stronger evidence than a case summary mention, a contract award inference, or even an OALJ decision party listing.
Why Are Coverage Cards the Strongest Carrier Evidence?
DBA carrier identification relies on a hierarchy of evidence. At the top sits direct documentation: a policy declaration page, a certificate of insurance, or an LS-570 filing. Below that, you find indirect evidence like DOL case summaries, OALJ decision party names, and contract award records that let you infer the carrier through the prime contractor.
Coverage cards outrank most other sources for three reasons. First, they are filed by the carrier itself with the federal regulator. The carrier is attesting, under regulatory obligation, that it provides DBA coverage for the named employer. Second, they include specific dates. You do not have to guess whether the relationship was active during your claimant's employment period. Third, they are not litigation artifacts. OALJ decisions only exist because someone filed a disputed claim. Coverage cards exist for every compliant carrier-employer relationship, disputed or not.
This matters because the majority of DBA employers never appear in OALJ decisions. ClaimTrove data shows over 51,000 unique employer names across FOIA-obtained federal insurance filings. Compare that to roughly 5,000 OALJ decisions. Coverage card data captures ten times the employer universe that litigation records cover.
When building your carrier investigation workflow, coverage cards should be the first source you check after ruling out mandatory agency contracts. If a valid card exists for your employer and time period, you may not need to go further.
What Problems Do Coverage Cards Create for Investigators?
Coverage cards sound like the answer to every DBA carrier question. In practice, they introduce their own set of challenges that can mislead investigators who take them at face value.
Employer name variations. The employer name on a coverage card is whatever the carrier submitted. That might be the company's legal name, a DBA, a subsidiary, or a misspelling. A single employer like DynCorp might appear as "DynCorp International," "DynCorp International LLC," "Dyncorp," or "DI Operating LLC" across different filings. ClaimTrove data reveals over 2,000 carrier name variations across FOIA-obtained filings, and employer names are even more inconsistent. Without alias resolution, you can search for the right company and find nothing.
Expired or missing cards. Carriers are supposed to file updated LS-570 forms when policies renew. Many do not. A card showing coverage from 2012 to 2013 does not necessarily mean coverage ended in 2013. It might mean the carrier simply never filed the renewal. Conversely, the absence of a card does not prove the employer was uninsured. It may mean the filing is sitting in a different district office or was never digitized.
Temporal gaps. Employers change carriers. A company insured by CNA in 2008 might have moved to Starr Indemnity by 2014 and to Zurich by 2019. Each shift creates a new coverage card, but the old cards do not get updated to show the end of that carrier's relationship. You might find three carriers for one employer and need to determine which one was active during your claimant's injury period. Understanding which database sources cover which time periods is critical for resolving these overlaps.
TPA confusion. Some coverage cards list a third-party administrator rather than the actual carrier. If you see Gallagher Bassett or ESIS on a filing, that is not the carrier. That is the claims handler. The actual carrier might be Starr Indemnity, ARCH Insurance, ACE, or Chubb. Mistaking a TPA for a carrier is one of the most common errors in DBA practice, and coverage cards can reinforce that mistake when the distinction between TPA and carrier is not clearly marked.
How Do You Access Coverage Card Data?
Here is the hard truth about LS-570 filings: there is no public search tool for them. The DOL does not offer a coverage card lookup on its website. The data lives in district office records, split between physical card files (pre-2012) and an internal digital system (post-2012) that has no external-facing interface.
The traditional path is a FOIA request to the DOL's OWCP division. You submit a request specifying the employer name and the district office, then wait. Response times vary from weeks to months. The results, when they arrive, may cover only one district office. If the employer operated in multiple jurisdictions, you may need separate requests to each office.
Even when you get results, you still face the name-matching and temporal challenges described above. A stack of coverage cards is only useful if you can cross-reference the employer names against known aliases and map the carrier names to current entities. A carrier listed as "Insurance Company of the State of Pennsylvania" in a 1990s filing is actually AIG. "Indemnity Insurance Company of North America" is ACE, now Chubb. Without a reference database of carrier families and historical names, individual FOIA results require significant manual research.
ClaimTrove indexes over 154,000 FOIA-obtained federal insurance filings spanning 78 years of coverage history. Instead of filing your own FOIA request and waiting months, you can search by employer name and instantly see historical carrier coverage, normalized carrier names, and coverage date ranges. Search coverage card records through ClaimTrove and skip the FOIA queue.
How Do Coverage Cards Fit Into the Broader Carrier Investigation?
Coverage cards are the strongest single source, but they work best as part of a layered investigation. No single data source covers every employer or every time period. The DBA insurance ecosystem is too fragmented for that.
Start with mandatory agency contracts. If the employer worked under a State Department, USACE, or USAID contract during a mandatory period, the carrier is predetermined. Coverage cards are irrelevant for those specific agency-period combinations.
For everything else, coverage cards should be your next check. If you find a valid filing matching your employer and time period, you have strong evidence. But verify it against at least one other source. Check DOL case summaries for the same employer-carrier pair. Look for the carrier in OALJ decisions involving that employer. Cross-reference the prime contractor's contract awards to confirm the employer was active during the coverage period.
When coverage cards produce no results, shift to indirect methods. Contract award records can identify the prime contractor, which narrows the carrier pool. DOL case summaries show which carriers have historically handled claims for that employer. OALJ decisions name carriers as parties in litigated claims. Each source fills gaps the others leave.
The attorneys who resolve carrier questions fastest are the ones who search multiple sources simultaneously rather than working through them one at a time. ClaimTrove runs this multi-source investigation in seconds, checking coverage card filings alongside 17 other federal databases. Run your first investigation free and see every source that mentions your employer.
What Should You Do When Coverage Cards Contradict Other Evidence?
Sometimes coverage cards point to one carrier while other evidence points to another. This is more common than most attorneys expect, and it usually traces back to one of three scenarios.
The first is a carrier transition. The employer changed carriers between policy periods, and your claimant's injury date falls near the boundary. Coverage cards show Carrier A through June 2015 and Carrier B starting July 2015. If the injury occurred in June but was not reported until August, both carriers may appear in the record. The coverage card dates are your best evidence for determining which carrier was on the risk at the time of injury.
The second is a corporate restructuring. The employer was acquired, merged, or reorganized, and the coverage card was filed under a predecessor name. The new entity may have a different carrier entirely. Tracing the corporate lineage is essential. ClaimTrove's alias resolution maps over 214 employer alias groups, connecting predecessor and successor names to the same investigation results.
The third is a TPA misidentification in the opposing evidence. A DOL case summary might list Gallagher Bassett as the "carrier" because that is who administered the claim. The coverage card correctly shows Starr Indemnity. In this scenario, the coverage card is right. The case summary reflects claims administration, not the insurance policy. Always trust the LS-570 over a case summary carrier name when they conflict.