illumend CEO: Manual COI Tracking Can Create Hidden Vendor Approval Risk

Kristen Nunery says spreadsheets, inboxes, reminders, and manual reviews may keep vendors moving, but they often fail to show why vendors were approved, delayed, escalated, or rejected

Key Takeaways

• Manual COI tracking may seem to work, but it often does not give teams real control.
• Spreadsheets, inboxes, reminders, and manual reviews can hide the context behind vendor decisions.
• The biggest risk is inconsistent vendor approval. Teams may struggle to explain what was checked, what was missed, and why a vendor moved forward.
• Modern COI compliance requires more than document tracking. Teams need a process that highlights issues, records decisions, and guides consistent approvals.
• AI-native COI compliance decisioning helps teams apply requirements consistently, document outcomes clearly, and maintain human oversight when exceptions, audits, re-reviews, or changes to decisions are needed.

INDIANAPOLIS, June 24, 2026 /PRNewswire/ -- Kristen Nunery, CEO of illumend™, the AI-native platform redefining how businesses manage third-party insurance compliance and risk, is encouraging businesses to reassess manual Certificate of Insurance (COI) tracking workarounds that appear to keep vendors moving but may create hidden approval risk.

In her new article, "The Manual COI Tracking Workaround Everyone Knows Is Risky, But No One Wants to Replace," Nunery argues that spreadsheet-based COI tracking often survives because it appears functional. Vendors send certificates, reviews happen, and contracts move forward. But behind that activity, teams may be relying on scattered records, hidden exceptions, and the memory of one or two people who know what the system cannot show.

"The hardest COI workarounds to replace are the ones that seem to be working," said Kristen Nunery, CEO of illumend. "They help teams get through the day, but they do not always give the organization real control. Manual tracking can show that a certificate was received, but it may not show what was checked, what was missed, or why a vendor was allowed to move forward."

Nunery says the problem is not spreadsheets themselves. The problem is using spreadsheets, inboxes, reminders, and company knowledge as if they were a full compliance system. A certificate may look current while the real requirement lives in a buried email. A vendor may have an undocumented exception. A project may require an endorsement that was never added to the spreadsheet.

Manual COI tracking becomes risky, Nunery says, when vendor approval decisions become inconsistent, hard to back up, or difficult to explain later.

"Tracking documents is not the same as managing compliance," Nunery said. "A team can collect a certificate and still miss a requirement. A current document may not include the needed coverage. A renewal can be tracked while a gap remains unresolved."

COI compliance requires teams to answer questions that document storage alone cannot resolve: Does the coverage meet the requirement? Is the policy type correct? Is the required endorsement included? Does the vendor satisfy the contract for this project, location, or scope of work? Who needs to act next?

Those questions, according to Nunery, require interpretation, not storage.

She says the challenge is especially acute for administrative, operations, finance, HR, project, and risk-adjacent teams that are expected to keep vendors moving even though they are not insurance specialists. These teams may have to decide whether a certificate is acceptable, whether a missing endorsement matters, whether a renewal creates risk, or whether a vendor can start work while someone else checks the details.

Nunery points to a common scenario: a subcontractor needs to start work, but the usual insurance reviewer is out. The certificate shows active coverage, but the contract requires an additional insured endorsement. One person remembers seeing the requirement in an email. Another checks the spreadsheet and finds only "COI received." The project manager wants to approve the vendor, but no one can confirm whether the endorsement is required, missing, waived, or already reviewed.

In that situation, the team did not fail. The process relied on one person's memory as the main control.

Nunery identifies five warning signs that a COI compliance workaround has reached its limit:

1. Too much depends on one or two people
2. The same information is entered in too many places
3. Compliance questions take too long to answer
4. Similar issues lead to different decisions
5. Follow-up work crowds out actual risk work

Once those signs appear, Nunery says the real question is not whether the workaround still functions. The question is whether it gives the organization enough accuracy, consistency, and control to continue doing the job well.

A better process moves from tracking documents to tracking decisions: what was submitted, what was reviewed, what does not match, who needs to respond, and whether the vendor can move forward.

That shift, Nunery says, is where AI-native COI compliance decisioning changes the workflow.

"AI only matters if it helps with the part of compliance that document tracking cannot solve: interpretation," Nunery said. "Teams are not just trying to find documents faster. They need to apply requirements consistently, document outcomes clearly, and keep the process moving with the right controls in place."

At illumend, that AI-native approach is powered by Lumie, illumend's built-in AI guide that automates every third-party vendor compliance, from contract upload to final approval. Lumie evaluates certificate of insurance documentation against an organization's requirements and determines whether a vendor is compliant, deficient, or requires exception handling.

Lumie makes the compliance decision, not merely organizing information for someone else to interpret. It evaluates submitted documents against applicable requirements, identifies whether coverage meets the standard, determines whether a vendor is compliant or deficient, and preserves the reasoning behind the decision.

For example, a claims-made policy submitted in response to an occurrence-based requirement can be flagged as non-compliant. A missing additional insured endorsement can trigger a request for corrected documentation. A coverage issue that requires business judgment can be routed for exception review with the underlying context already documented.

With illumend, vendor records, submitted certificates, project requirements, prior exceptions, expiration status, deficiency history, and review activity are brought together into a single connected workflow. If a project requires an additional insured endorsement and the submitted documentation does not satisfy that requirement, Lumie determines the compliance status, documents the reason, and advances the next step: request corrected documentation, route an exception for approval, or record the decision if an exception has already been approved.

The illumend workflow changes the work from "find the answer" to "manage the outcome with the right decision, context, and controls."

Built on 16 years of insurance compliance expertise from myCOI, illumend combines institutional knowledge with an AI-native platform that supports the compliance lifecycle. The platform connects vendor records, submitted documents, insurance requirements, deficiency alerts, renewal monitoring, exception handling, and resolution activity, so teams can see not only whether a document exists, but also whether the vendor is ready for approval.

"Companies do not outgrow spreadsheets because they are tired of them," Nunery said. "They outgrow them because the risk becomes too important to manage from memory. The goal is to stop asking people who are not insurance experts to make insurance compliance decisions through scattered tools, memory, and guesswork. A better process gives those people what they need most: consistent compliance decisions, documented reasoning, and auditable outcomes."

To read Nunery's full article, visit https://www.linkedin.com/pulse/manual-coi-tracking-workaround-everyone-knows-risky-one-nunery-lmfie/.

Organizations considering a switch to AI-powered COI process management software can learn more about illumend's approach to third-party insurance compliance at https://www.illumend.ai.

Frequently Asked Questions

When should a company replace a manual COI tracking workaround?
A company should replace a manual COI tracking workaround before it fails under pressure. Warning signs include overreliance on one or two people, duplicate data entry, slow responses to basic compliance questions, inconsistent decisions on similar issues, and excessive follow-up work that crowds out actual risk work.

Why is spreadsheet COI tracking risky?
Spreadsheet COI tracking can show that a certificate was received without showing whether coverage was reviewed against the right requirement, whether an endorsement was missing, whether an exception was approved, or why a vendor was allowed to move forward.

What does AI-native COI compliance decisioning mean?
AI-native COI compliance decisioning means using AI to evaluate submitted insurance documentation against applicable requirements, determine whether a vendor is compliant or deficient, document the reason for the outcome, and route the workflow to the appropriate next step.

How does Lumie help with COI compliance?
Lumie is illumend's built-in AI guide that automates every third-party vendor compliance step from contract upload to final approval. Lumie evaluates COI documentation against an organization's requirements, determines whether a vendor is compliant, deficient, or requires exception handling, and preserves the reasoning behind the decision.

About illumend
Founded in 2025, illumend™ is the AI-powered platform redefining how businesses manage third-party insurance compliance and risk. Backed by myCOI, the leader in third-party insurance compliance management with more than 16 years of expertise, illumend reimagines compliance by guiding every step of the process—from document review and expiration tracking to risk flagging, communication, and resolution—within one intuitive system. Built on myCOI's institutional foundation—having processed more than 45 million documents, managed over 1.2 million agreements, cleared more than 750,000 third-party partners, and identified more than two million coverage gaps before claims—illumend brings this depth of compliance intelligence into an AI-native platform. At its core is Lumie, illumend's conversational AI guide that reads complex insurance documents, flags issues in real time, and explains them in language anyone can act on. To learn more, visit https://www.illumend.ai.

Media contact:
Michael Tebo
Gabriel Marketing Group (for illumend)
Phone: 571-835-8775
Email: [email protected]

SOURCE illumend