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Life and Health News

March 2026

Welcome to our latest newsletter! As a thought leader in the Insurance Industry for over 50 years, we are always excited to share the latest sampling of insurance compliance related bulletins, regulations, and legislative activity. Please feel free to share this newsletter with others that may be interested. Contact Us with any questions on the items in this newsletter or with any other compliance related matter we can assist you with. Enjoy!

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AFFORDABLE CARE ACT

Maryland published a bulletin providing guidance on filing requirements for individual and small employer health and stand-alone dental plans for the 2027 ACA policy year. The bulletin sets deadlines for forms and rate submissions, specifies required documentation including actuarial value, prescription drug benefit certifications, MHPAEA compliance, and Unified Rate Review Templates, and clarifies that essential health benefits remain unchanged except for presumptively discriminatory benefits.     Bulletin 26-6

United States Centers for Medicare and Medicaid Services issued guidance for 2027 ACA payment parameters, setting the premium adjustment percentage at 89.2%, the maximum annual cost-sharing limits at $12,000 for self-only and $24,000 for other coverage, and the required contribution percentage for affordability exemptions at 8.50%. NHEA projections and ACA rules are used to determine cost-sharing, employer responsibility payments, and eligibility for catastrophic coverage.     CMS Notice Dated 1/29/26

United States Centers for Medicare and Medicaid Services released the key operational dates for 2026, covering Qualified Health Plan (QHP) certification, rate review, form review, and risk adjustment. Major deadlines include QHP applications, rate justifications and determinations, form filings, and risk adjustment submissions and payments, with Open Enrollment and public quality ratings starting November 1, 2026.     CMS Notice Dated 2/23/26

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CAPTIVES

Utah amended its rules for captive insurers, moving the Statement of Actuarial Opinion filing deadline to June 30 to align with the annual audit and clarifying that the Statement of Economic Benefit to the State of Utah must be included in the annual report. The rules specify that both the audit and actuarial opinion are part of the company’s annual financial condition report.     R590-238-4

Vermont released guidance on credit for reinsurance for captive insurers, detailing requirements for recognizing reinsurance recoverables, transferring risk to qualified reinsurers, and maintaining sufficient security to ensure claims are paid. The bulletin clarifies filing obligations, approval processes for structural changes or affiliated reinsurers, and compliance expectations for both statutory and GAAP filers, while discontinuing the Captive Division’s published list of authorized reinsurers for years ending December 31, 2025, and beyond.     Notice Dated 1/28/26

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CYBERSECURITY

Delaware reissued a bulletin to remind insurance entities of their obligations under the Delaware Insurance Data Security Act. The Act requires insurers, producers, brokers, agents, underwriters, and contractors to implement information security programs, oversee third-party providers, investigate cybersecurity events, notify the DOI within three business days, and provide impacted consumers with one year of free credit monitoring.     Universally Applicable Bulletin 5 (Reissued)

New York released a cybersecurity advisory warning regulated entities of an active vishing campaign in which attackers impersonate IT help desk staff, use spoofed caller IDs, and direct employees to malicious login pages to capture credentials and MFA codes. DFS urges entities to strengthen defenses through identity verification, targeted training, access management, MFA enrollment, and continuous monitoring. Suspected incidents should be investigated and reported to both the FBI’s Internet Crime Complaint Center and DFS.     Industry Letter Dated 2/6/26

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DENTAL INSURANCE

New Mexico established new dental provider credentialing requirements, applying to all dental health insurance carriers offering network-based individual or group plans. The rules cover initial and re-credentialing, timely payment for covered services, claim submission and coding standards, and a uniform dispute resolution process, while clarifying that carriers are not required to credential providers, set reimbursement rates, or interpret member contracts.     13.10.37.1 NMAC

North Dakota published a bulletin explaining dental loss ratio reporting requirements, applying to all insurers with dental experience in the individual, small group, and large group markets. Insurers must submit annual reports through SERFF by April 30, with 2026 filings covering 2024–2025 data, using separate Excel spreadsheets for each market that include policyholder counts, member months, DLR numerator and denominator, dental loss ratios, and total aggregate expenses.     Bulletin 2026-1

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DRUG / PRESCRIPTION COVERAGE

West Virginia clarified that prescription drug rebates must be applied at the point of sale to reduce individual cost sharing and that any excess rebates must lower plan premiums rather than being retained by PBMs. The issued bulletin explains insurer filing requirements to show how rebates affect rates, summarizes rebate impacts for 2024–2026 plan years, and reiterates compliance with the Pharmacy Audit Integrity Act amendments.     Bulletin 2026-01

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FILING REQUIREMENTS / PROCEDURES

Mississippi issued a bulletin establishing the Product and Rate Filing Fee Schedule for expedited review of life, credit life, annuity, and accident and health insurance filings. The bulletin provides detailed fees based on the degree of analysis required, ranging from $215 for low-complexity filings to $1,675 for extremely high-complexity filings, with specific classifications for individual and group policies, riders, annuities, and accident and health forms. Insurers opting for expedited review must adhere to the schedule in Section 2 and Exhibit “A.”     Bulletin 2026-2

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FILINGS: HEALTH

South Carolina’s Department of Insurance now requires all Medicare Supplement rate filings effective March 4, 2026, and later to include a new Excel exhibit, which is available on the Department’s website.     Notice Dated 2/19/26

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HEALTH CARE EXCHANGE / MARKETPLACE

Oklahoma announced its transition to a State-based Exchange on the Federal Platform (SBE-FP) starting May 1, 2026, with a full State-based Exchange (SBE) launching for the 2028 plan year. During the SBE-FP period, HealthCare.gov will continue to handle enrollment while Oklahoma assumes functions such as plan management, consumer assistance, marketing, and hotline operations, with full control of all Exchange operations expected in 2028.     Notice Dated 2/10/26

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HEALTH INSURANCE - COMPREHENSIVE

California issued guidance clarifying large group renewal notice requirements under the Health and Safety Code to ensure timely and transparent disclosure of premium rate and coverage changes. The guidance requires plans to provide renewal notices at least 120 days before renewal, include specific rate comparison information, and inform contract holders of their right to request a rate review within 60 days.     DMHC APL 26-003

Connecticut requires health carriers to comply with section 8 of Public Act 25-167 regarding credit for certain out-of-pocket prescription drug purchases. The requirement applies to individual and group health policies issued or renewed on or after January 1, 2026, and takes effect July 1, 2026, mandating that carriers credit qualifying direct payments to licensed providers toward in-network cost sharing. Carriers must also publish a proof of payment form and provide annual instructions to insureds for submitting eligible claims.     Notice Dated 2/17/26

Michigan released guidance on the annual deductible adjustment for Qualified Health Coverage under Public Acts 21 and 22 of 2019. The bulletin explains that the Director adjusts the maximum deductible based on changes in the medical component of the Consumer Price Index, but only if the adjustment meets a $500 threshold. For July 1, 2026, through June 30, 2027, the maximum deductible for QHC remains $6,579.     Bulletin 2026-08-INS

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HOLDING COMPANIES

Alabama adopted new regulations to incorporate the NAIC’s group capital calculation framework for insurance holding company systems. The regulation allows the lead state commissioner to grant exemptions or accept limited filings based on specified premium thresholds, organizational structure, and risk factors. It also establishes standards for recognizing and accepting group capital calculations from qualifying non-U.S. jurisdictions through regulatory acknowledgment and information-sharing agreements.     Reg. 482-1-055-18.2

Ohio updated its insurance holding company system regulations, amending rules governing acquisitions (Form A), annual registration and reporting (Forms B, C, and F), affiliated transactions (Form D), managing general agent licensing, examination work paper definitions, and ceding insurer reinsurance credit. The changes aim to enhance transparency, financial stability, and policyholder protection while aligning with NAIC model regulations and statutory requirements.     Rule 3901-3-01

Virgin Islands' Division of Insurance and Financial Regulation issued a bulletin providing interim guidance on compliance with Act No. 9073, which amends the Insurance Holding Company System Regulatory Act to require group capital calculations, liquidity stress testing, and receivership provisions. The bulletin outlines filing deadlines, exemptions, recognition of non-U.S. jurisdictions, and revised prior notice requirements for transactions, dividends, and other distributions, with the first annual group capital calculation due in 2026.     Bulletin 2026-02

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MISCELLANEOUS HEALTH / ACCIDENT

District of Columbia enacted a bill under the Universal Paid Leave Amendment Act to protect workers by ensuring short-term disability insurance benefits cannot be reduced or offset due to benefits received under the DC paid leave program. The legislation prohibits insurers from reducing benefits under any temporary or short-term disability policy, regardless of where the policy was issued, executed, written, or delivered, and clarifies relevant definitions and coordination rules.     B 573

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PHARMACY BENEFIT MANAGERS

Louisiana released a directive to pharmacy benefit managers (PBMs) and health insurance issuers to clarify reimbursement of professional dispensing fees under Act 474. The directive requires PBMs to use a reimbursement formula combining a NADAC-based drug price, an adjustment factor, and a professional dispensing fee, and sets a minimum fair and reasonable reimbursement of NADAC + $9.00 for a 30-day supply.    Directive 257

Maine amended its insurance regulations to align with Public Law 2025, Chapter 291, prohibiting pharmacy benefits managers (PBMs) from engaging in spread pricing in state-regulated health plans, except for MaineCare. The amendments revise the definition of “spread pricing,” remove any references to generating savings from spread pricing, and explicitly bar carriers and PBMs from facilitating or entering contracts involving spread pricing, directly or indirectly. Carriers and PBMs must submit an annual CEO- or CFO-signed certification by December 31 confirming full compliance with the prohibition.     Insurance Rule Ch. 210 s 1

Massachusetts implemented new regulations to establish reporting requirements for pharmacy benefit managers (PBMs). The regulation requires PBMs to submit data on wholesale acquisition costs, formulary and maximum allowable cost lists, discounts, utilization limits, rebates, and administrative service fees, enabling the Department to analyze drug pricing, track rebate trends, and assess amounts retained or passed through to health plans.     957 CMR 12.01

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PRE-NEED CONTRACTS

North Carolina strengthened its regulations regarding compliance and transparency in preneed trust fund transfers between financial institutions. Preneed licensees must now direct funds to transfer directly and solely from the original to the substitute institution, eliminating intermediary handling, and notify the Board within 10 days using a prescribed form. The form must include detailed information on the licensee, preneed contract, financial institutions, beneficiaries, and signatures attesting to the transfer and receipt of funds,.     21 NCAC 34D .0304

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REGULATORY REPORTING REQUIREMENTS

Arkansas issued a bulletin clarifying pharmacy network adequacy data submission requirements for issuers that use pharmacy benefit managers. The bulletin reiterates that issuers must file an annual pharmacy network adequacy report by March 1 each year, covering data from the prior calendar year. It emphasizes that while PBMs may assist, issuers remain fully responsible for timely, complete, and accurate filings.     Bulletin 2-2026

Delaware revised its bulletin to require all admitted and approved domestic and foreign insurers to provide direct telephone numbers and e-mail addresses for employees corresponding with the DOI, improving communication efficiency during consumer complaint investigations. The revision extends this requirement to all contact types listed on UCAA Form 14, mandates updates within 30 days of personnel changes (with immediate updates for Catastrophe/Disaster Coordination contacts), and encourages annual reviews of contact information in State-Based Systems.     Domestic-Foreign Insurers Bulletin 98 (Revised 2)

Illinois published a bulletin to update filing instructions for annual insurance supplier diversity reports. The bulletin applies to insurers, HMOs, limited health service organizations, dental service plan corporations, and accredited reinsurers with at least $50 million in net admitted assets, detailing how to complete and submit reports through SERFF using the designated TOI/sub TOI for supplier diversity. Illinois requires accurate reporting of procurement categories, inclusion supplier types, and any unusual circumstances, with the first report due April 1, 2026.     Bulletin 2026-03

Massachusetts issued guidance for health insurance carriers regarding compliance with state and federal mental health parity laws, including the Mental Health Parity and Addiction Equity Act, for benefits provided in 2025. Carriers must submit filings through SERFF by July 1, 2026, including a CEO- and CMO-signed Certification of Compliance along with comparative analyses of nonquantitative treatment limitations.     HC Filing Guidance Notice 2026-A

Missouri released a bulletin reminding insurers of their annual statistical reporting obligations for all lines of insurance, including property, casualty, life, health, and accident, without introducing new requirements. The bulletin provides filing deadlines, statutory references, and submission methods, including online submission via the DOI’s portal and e-mail for certain ZIP code data.     Bulletin 26-03

New York issued a liquidity and severe mortality inquiry to all licensed life insurers and accredited life reinsurers to assess stress liquidity exposure and financial flexibility. Insurers must submit responses by May 1, 2026, through DFS’s secure portal, detailing liquidity plans, stress testing, yield-enhancing activities, rating agency findings, reinsurance agreements, illiquid assets, guarantees, and preparedness for severe mortality events. The inquiry requires disclosure of formal liquidity plans, alternative cash-raising methods, portfolio yield impacts, reinsurance and guarantee exposures, and potential large or institutional cash demands.     Liquidity and Severe Mortality Inquiry - 2026

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REPORTS - DATA CALLS & OTHER REPORTS

Pennsylvania requires insurers to submit Medicare Supplement refund calculation data by May 31, 2026, for standardized and pre-standardized plans using the DOI’s Excel workbook via SERFF. Filings must preserve formulas, report experience separately for standard/select and pre-standardized plans, and include explanations for any discrepancies from prior submissions.     2026 Medicare Supplement Data Call

Puerto Rico’s Insurance Commissioner requires all health service organizations and insurers to submit health data on women of reproductive age, infants, children, and adolescents covered during July 1, 2024–June 30, 2025, using Department of Health forms.     Circular Letter CC-2026-2058-AF

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RESERVE VALUATION

Oklahoma adopted the NAIC 2025 Valuation Manual amendments for life and accident & health insurers. The Order formalizing adoption is available on the Oklahoma Insurance Department website, and insurers with questions may contact their assigned financial analyst.     Notice Dated 2/11/26

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TRADE PRACTICES

California amended its Civil Code and the Military and Veterans Code to strengthen protections for service members and veterans against deceptive practices, unreasonable fees, and exploitation related to veterans’ benefits and services. The bill expands the definition of public social services to include a broader range of veterans’ benefits, limits fees for veterans’ benefits to amounts permitted under federal law, and clarifies prohibitions on accessing Common Access Cards or requiring login credentials for federal systems.     SB 694

Texas amended its trade practices rules to expand out-of-network provider disclosures, claim dispute resolution, and EMS rate and payment requirements, including applying these rules to higher education health plans. Amendments clarify mediation deadlines, EOB instructions, balance billing protections, and EMS rate submissions, with limits on annual rate adjustments and enforcement through audits and the Texas Open Data Portal.     28 TAC s 21.4902

 

Life and Health News

February 2026

Welcome to our latest newsletter! As a thought leader in the Insurance Industry for over 50 years, we are always excited to share the latest sampling of insurance compliance related bulletins, regulations, and legislative activity. Please feel free to share this newsletter with others that may be interested. Contact Us with any questions on the items in this newsletter or with any other compliance related matter we can assist you with. Enjoy!

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AFFORDABLE CARE ACT

U.S. Center for Medicare and Medicaid Services issued guidance updating the HHS-developed risk adjustment methodology and DIY software for the 2025 benefit year applicable to ACA-compliant individual and small group health plans. The bulletin outlines technical updates to risk adjustment models, classifications, tables, and software tools, including revisions related to sickle cell disease, recalibration using EDGE data, and ongoing use of the high-cost risk pool.     CMS Notice Dated 1/23/26

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AGENT / PRODUCER CONTINUING EDUCATION

Illinois updated its regulations to align pre-licensing and continuing education (CE) requirements for insurance producers, limited insurance representatives, and business entities with the NAIC Continuing Education Reciprocity (CER) Agreement. Revisions clarify definitions, require submission of CER Course Filing Forms, outline provider and applicant responsibilities, and set standards for course content and delivery. Updates also revise Exhibits E and H to include indexed life policies and ride-sharing coverage.     50 Ill. Adm. Code 3119.20

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AGENT / PRODUCER LICENSING AND APPOINTMENT

Iowa announced updates to licensing and reporting processes for preneed sellers, sales agents, insurers, and financial institutions. Beginning February 13, 2026, preneed seller and sales agent license applications and renewals will be submitted through NIPR LicenseHub, and required annual reports must be filed electronically through OPTins, with sales agents no longer required to submit annual reports.     Bulletin 26-01

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AGENT / PRODUCER TERMINATION

Maryland released a bulletin outlining how insurers must notify the Insurance Commissioner when a producer’s appointment is terminated for cause. Insurers may submit the required notice and supporting documentation either through the Administration’s online enforcement intake form or by email to the Fraud and Enforcement Division.     Bulletin 26-3

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CYBERSECURITY

Missouri issued guidance on the Insurance Data Security Act, requiring regulated entities to report cybersecurity events using the Department’s electronic form, including events involving third-party service providers. The bulletin clarifies which entities qualify as licensees and aligns Missouri’s implementation with NAIC Model Law 668.     Bulletin 26-01

New York released a warning about a phishing scam targeting DFS-regulated entities, emphasizing that legitimate DFS emails only come from @dfs.ny.gov or @public.govdelivery.com domains. Recipients are advised to verify unexpected requests for payments or sensitive information, avoid links in suspicious emails, and follow cybersecurity best practices.     Industry Letter Dated 1/22/26

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DISASTER / CATASTROPHIC EVENT

Maryland issued a bulletin in response to a declared State of Emergency requiring health carriers to waive time restrictions on prescription medication refills and to cover pharmacy fills of at least a 30-day supply, regardless of the last fill date. The waiver applies to insurers, nonprofit health service plans, HMOs, dental plan organizations, and the Maryland Health Insurance Plan.     Bulletin 26-4

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HEALTH INSURANCE - COMPREHENSIVE

Georgia released a bulletin prohibiting step therapy for stage-four metastatic cancer. All health benefit plans, including state employee and Medicaid managed care plans, must cover FDA-approved drugs for this condition without requiring patients to try other drugs first, though plans may verify that use aligns with best practices and peer-reviewed guidance.     Bulletin 25-EX-6

Michigan updated the annual co-pay and coinsurance cap for orally administered antineoplastic medications to $254.75 for 2026, reflecting changes in the U.S. prescription drug index. Health insurers must apply this cap to ensure compliance with state law under MCL 500.3406ff(1)(b).     Bulletin 2026-02-INS

New Jersey enacted legislation amending multiple insurance and health benefits statutes to require a wide range of health carriers to cover one annual wellness visit per plan year or calendar year for individuals over age three, with no waiting periods permitted. The requirement applies across individual, group, small employer, HMO, and state employee and school employee health benefit plans, and applies to policies or contracts issued or renewed on or after the bill’s operative date.     AB 5785

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HOLDING COMPANIES

Alabama released a bulletin to advise domiciled insurers subject to the group capital calculation that the Department now follows the filing requirements in NAIC Model Regulation No. 450, including authority to exempt, limit, or require filings for insurance groups. A hearing is scheduled for February 5, 2026, to consider adopting new Section 18.2 of Alabama Insurance Regulation 55, which will codify these filing requirements effective February 15, 2026.     Bulletin 2026-01

Arkansas updated its regulations for Insurance Holding Company Systems, modernizing prior notice transaction rules and group capital calculation requirements to align with NAIC standards. The amendments clarify filing procedures, ownership and control of insurer records, termination and indemnification standards, and cooperation obligations during supervision or receivership, while also establishing criteria for exemptions or limited filings for group capital calculations.     23 CAR s 9-118

Florida adopted new requirements under the Insurance Holding Company System Regulatory Act, including group capital calculations and liquidity stress tests. The rule introduces two new NAIC-aligned templates: the Group Capital Calculation 2024 Template and the Liquidity Stress Test 2024 Template.     FAC Rule 69O-143.046

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MEDICARE SUPPLEMENT INSURANCE

Delaware published a bulletin informing Medicare Supplement carriers and producers of Senate Bill 71, which establishes Guaranteed Issue Special Enrollment Periods (SEPs) for existing policyholders around their birthdays and for individuals transitioning from Medicare Advantage to Original Medicare. Carriers must notify eligible policyholders, honor Guaranteed Issue rights without denying coverage, adhere to existing rating rules, and ensure marketing, underwriting, and training comply with the law.     Domestic and Foreign Insurers Bulletin No. 164 & Producer and Adjuster Bulletin No. 40

Nevada issued guidance on Senate Bill 292, requiring insurers offering Medicare supplement policies to provide coverage to individuals under 65 who qualify for Medicare due to disability or end-stage renal disease on the same terms as those 65 or older. Non-compliance may violate SB292 and the state’s Unfair Trade Practices Act, subjecting insurers or producers to investigations, administrative actions, or market conduct examinations.     Bulletin 25-006

Vermont clarified that Medicare Supplement policyholders who turn 65 must be automatically moved from disability-rated risk pools to age-based pools, as continuing to charge disabled rates violates community rating and constitutes unfair discrimination. Insurers must reflect compliance in annual rate filings and notify affected policyholders before their 65th birthday.     Bulletin 208 (Revised)

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MISCELLANEOUS

Illinois now allows insurance companies the option of issuing checks signed by the company name rather than a corporate officer or employee. The revision is intended to enhance security and protect officers and employees from potential risks associated with check issuance.     50 Ill. Adm. Code 904.30

Illinois published a bulletin guiding health insurers on implementing the Uniform Electronic Provider Directory Information Forms (Uniform Directory Template). Issuers must adopt the template by July 1, 2026, verify provider information at least every 90 days, allow providers to update directory data via the template, and ensure no additional information outside the prescribed template is required for NATA-regulated directories.     Bulletin 2025-23

Maryland confirmed that the USPS Intelligent Mail Barcode qualifies as a valid “first-class tracking method” under section 1-101 (m-1) of the Insurance Article. This method provides evidence of the date first-class mail is accepted by USPS, supports multiple postal service programs, improves visibility of mail pieces, and may be used whenever a first-class tracking method or certificate of mailing is required.     Bulletin 26-2

Puerto Rico amended its Prescription Drug Price Transparency Act to refine retail drug price reporting by pharmacies, focusing on a statistically valid sample of the 100 most frequently prescribed brand-name and generic medications for uninsured patients with retail values over $100. The amendments adjust pharmacy reporting frequency, enhance confidentiality protections, revise the interagency committee’s composition and duties, and require regular public publication of comparative drug price information.     HB 1

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MISCELLANEOUS HEALTH / ACCIDENT

Arizona issued guidance to ensure compliance with H.B. 2144, requiring insurers to cover biomarker tests that demonstrate clinical utility for diagnosing, treating, managing, or monitoring diseases. The bulletin clarifies that insurers must align policies, guidelines, and manuals with statutory requirements, avoid imposing additional conditions, and provide supporting evidence when denying coverage.     Bulletin 2026-01

Oklahoma issued an executive order strengthening oversight of Medicare Advantage plans by imposing new requirements related to provider contracting, payment practices, marketing conduct, solvency, transparency, and network adequacy, with enhanced protections for rural providers. The order requires annual written provider agreements, limits inducements and marketing abuses, and mandates prompt payment and reporting to regulators.     Executive Order 2026-01

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REGULATORY REPORTING REQUIREMENTS

Maryland released a bulletin requiring all insurers, HMOs, dental plans, nonprofit health service plans, and premium finance companies to update their contact information and disaster-related contacts by April 15, 2026, via the Administration’s online portal. Primary contacts must review and save all information, even if no changes are necessary, and either primary or backup contacts must be available evenings or weekends. Updates must include disaster response plans, continuity of operations plans, pandemic flu plans, and severe event data call contacts.  CMS Notice Dated 1/23/26

New Hampshire issued guidance clarifying the format, timing, and method for annual submission of complaint and appeal information by health carriers, managed care plans, and utilization review entities as part of ongoing market-conduct oversight. Beginning with the April 1, 2026 filing, covered entities must submit an annual electronic summary of complaint and appeal data for the prior calendar year using a standardized DOI template, with the initial filing covering calendar years 2024 and 2025.     Bulletin INS 26-001-AB

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REPORTS - ANNUAL / QUARTERLY STATEMENT

Connecticut issued a bulletin detailing 2026 electronic filing requirements for annual and quarterly financial statements for all authorized insurers, surplus lines insurers, fraternal benefit societies, and health care centers. Filings must follow NAIC instructions and valuation standards, include retention of assets statements, and comply with applicable reinsurance credit regulations, with annual statements due March 1, 2026.     Bulletin FS-4-25

Kentucky updated its annual filing instructions to require all insurers to submit specified documents electronically via the eServices portal, effective 2025. Required filings include the Jurat Page, Certificates of Advertising or Deposit, annual and quarterly statements, actuarial certifications, and supplemental policy data. Penalties for late filings range from $100 per day to potential revocation of the Certificate of Authority, and all payments, including renewal fees, must be submitted online.     Notice Dated 1/8/26

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REPORTS - DATA CALLS & OTHER REPORTS

Arkansas issued a bulletin requiring commercial health insurers offering primary care benefits to submit primary care and medical spending data using the Arkansas Primary Care Payment Improvement Data Collection Template approved by the Primary Care Payment Improvement Working Group. Insurers must submit complete data by February 6, 2026, to allow the Working Group to analyze it and submit recommendations on primary care spending targets to the General Assembly by April 1, 2026.     Bulletin 1-2026

Utah updated its instructions and forms for the 2025 Accident & Health Survey, a mandatory annual filing for insurers reporting accident and health business in the state. The survey, including the Stop Loss and ASO supplements, must be submitted electronically by April 1, 2026, and late filings may incur penalties under Utah law.     Notice Dated 1/26/26

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STANDARD VALUATION LAW

Connecticut published a bulletin certifying that the 2025 updates to the NAIC Valuation Manual meet the requirements of Conn. Gen. Stat. § 38a-78a(b)(1). Insurers writing life, accident, health, and deposit-type contracts must comply with the revised principle-based reserving requirements.     Bulletin FS-50

New York updated its valuation regulation to incorporate the 2025 NAIC Valuation Manual by reference for purposes of principle-based reserving. The amendment revises the Superintendent’s authority provisions to replace references to the 2024 Valuation Manual with the 2025 version.     11 NYCRR 103.3

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TAX CREDITS

Georgia issued a bulletin specifying documentation requirements for claiming Georgia Housing Tax Credits on annual premium tax returns. Insurers must submit a completed Form IT-HC, partnership K-1 equivalents, and a detailed property schedule with building-level allocations.     Bulletin 25-EX-5

 

Life and Health News

January 2026

Welcome to our latest newsletter! As a thought leader in the Insurance Industry for over 50 years we are always excited to share the latest sampling of insurance compliance related bulletins, regulations, and legislative activity. Please feel free to share this newsletter with others that may be interested. Contact Us with any questions on the items in this newsletter or with any other compliance related matter we can assist you with. Enjoy!

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AFFORDABLE CARE ACT

New York released guidance clarifying grace periods, claims handling, and payment methods for ACA-compliant individual and small group plans in the NYSOH marketplace. Insureds receiving APTC have a 90-day grace period with specific claim payment rules, while those without APTC have a 30-day period; partial payments may be allowed under a 95% threshold, with shortfalls applied to future premiums. Plans must notify providers, prevent balance billing during grace periods, and accept multiple payment methods.     Filing Guidance Dated 12/4/25

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ARTIFICIAL INTELLIGENCE

Hawaii issued a memorandum providing guidance on the responsible use of Artificial Intelligence (AI) systems by insurers, emphasizing compliance with state laws on unfair trade practices, discrimination, and market conduct. Insurers are required to develop and maintain an AIS Program addressing governance, risk management, internal audits, transparency, and consumer protections, including oversight of third-party AI systems, documentation, and validation processes.     Memorandum 2025-13A

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DENTAL INSURANCE

Kentucky issued a bulletin guiding implementation of HB 210, establishing a uniform dental benefit assignment form that allows covered persons to assign dental insurance payments to out-of-network providers. The form outlines provider and insurer obligations, including notices, refunds, and revocation rights, while clarifying that carriers must honor assignments, but covered persons remain responsible for cost-sharing and uncovered charges.     Bulletin 2025-05

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FILING REQUIREMENTS / PROCEDURES

Hawaii announced the reorganization of the Insurance Division’s Rate and Policy Analysis Branch into two specialized units: the Life and Accident & Health Filings Branch and the Property and Casualty Filings Branch. The restructuring aims to improve regulatory oversight, enhance the timeliness and quality of filing reviews, and align the division’s operations with industry best practices.     Memorandum 2025-12R

Maryland issued a bulletin providing guidance on form and rate filing requirements for student health benefit plans for the 2026–2027 school year. Insurers must submit filings for new or amended forms or rate changes by February 2, 2026, ensuring compliance with federal and state laws, including step therapy limits, preventive service guidelines, copay accumulator rules, MHPAEA, and PPACA rating requirements, while demonstrating essential health benefit coverage and minimum actuarial value.     Bulletin 25-17

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HEALTH INSURANCE / HEALTH RATES

Arizona released guidance to insurers marketing and selling Short-Term, Limited Duration Insurance (STLDI) plans, clarifying enforcement of federal notice requirements and compliance expectations following recent federal agency guidance and rule changes. The Department of Insurance will enforce enhanced consumer notice and disclosure requirements but will not enforce federal term and duration limits, while emphasizing transparency, consumer education, and prohibitions on marketing STLDI as comprehensive major medical coverage.     Bulletin 2025-12 (INS)

New Jersey clarified that carriers must continue to cover childhood immunizations, including the hepatitis B vaccine at birth, as recommended by the New Jersey Department of Health, without cost-sharing or additional barriers. Carriers may not impose prior authorization, restrictive site-of-service policies, or other administrative requirements that limit access, and are expected to encourage plan sponsors of non-state-regulated plans to follow these standards.     Bulletin 25-11

Vermont updated Bulletin 171 to clarify the application of out-of-pocket maximums for prescription drugs under Insurance Code Section T.8 §4092. The bulletin provides FAQs addressing which drugs and expenses count toward out-of-pocket limits, how the rules apply to HDHPs and Health Savings Accounts, plan applicability, and references IRS guidance for dollar thresholds.     Bulletin 171 (Revised)

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HOLDING COMPANIES

Mississippi amended its insurance holding company regulation to align with the NAIC Model, updating requirements for cost-sharing and management service agreements and establishing provisions for group capital calculations. Changes include exemptions and limited filings for the annual group capital calculation, criteria for recognizing non-U.S. jurisdictions, and renumbering provisions concerning adequacy of surplus, with all new and renewal reinsurance transactions after July 1, 2017, required to comply.     19-1-20.19

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INTERNAL AND EXTERNAL REVIEW

California issued an All-Plan Letter notifying licensed health plans that Managed Medical Review Organization, Inc. (MMRO) has been added as a contractor, alongside MAXIMUS, Inc., to conduct Independent Medical Reviews under existing statutes and regulations. The IMR process itself remains unchanged, and plans must continue to provide required records and documents within applicable timeframes.     DMHC APL 25-017

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MEDICARE SUPPLEMENT INSURANCE

Colorado issued a bulletin addressing unfair trade practices related to Medicare Advantage and Medicare Supplement products, clarifying that actions restricting enrollment access or manipulating producer compensation may violate state insurance law. The bulletin applies to all carriers and producers and requires insurers to maintain accessible enrollment applications, avoid discouraging sales or enrollment, and adhere to approved compensation structures.     Bulletin B-4.157

Vermont released a notice explaining guaranteed issue rights and Medicare Supplement plan options for individuals in different scenarios, as many insurers have exited the state’s Medicare Advantage marketplace. Coverage availability depends on when a person became eligible for Medicare and includes special rules for newly eligible individuals, who have a six-month guaranteed issue window around their 65th birthday (or 24 months after a disability determination).     Notice Dated 11/25/25

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MISCELLANEOUS HEALTH / ACCIDENT

California issued an All-Plan Letter addressing amendments to network adequacy standards and methodologies affecting the 2026 Annual Network Review, including updates for mental health network availability, out-of-network care arrangements, provider data accuracy, and block transfer requirements. The guidance clarifies definitions, updates regulatory citations, and instructs plans to revise documentation and submit required filings through the DMHC e-Filing portal.     DMHC APL 25-

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OMNIBUS LEGISLATION

Illinois updated multiple sections of its Insurance Code to expand preventive health coverage, mandate vaccination administration fee coverage, strengthen PBM contract and reporting requirements, clarify licensure and refund processes, define unfair insurance practices, update pharmacy practice definitions, and establish a pharmacy support grant program. The changes include cost-sharing protections for immunizations, restrictions on PBM practices and drug access, updated reporting and licensure obligations, and grants to improve pharmacy access in underserved areas.     HB 767

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PHARMACY BENEFIT MANAGERS

Alaska issued a bulletin providing guidance on SB 132, updating licensing, fees, definitions, and examination requirements for Pharmacy Benefits Managers, Third-Party Administrators, Independent Adjusters, and other insurance entities to promote compliance and national uniformity. The bulletin establishes new PBM and TPA licensure standards, expands nonresident and designated home state licensing for independent adjusters, removes certain exemptions and physical location requirements, and updates lines of authority and compliance officer rules.     Bulletin B 25-09

Arizona adopted Article 25 establishing licensing, operational, compliance, and recordkeeping standards for pharmacy benefit managers, including certificate of authority requirements, biennial renewals, utilization review obligations, and defined record-retention periods. The rules set a $500 non-refundable application and renewal fee, require notices for material modifications, and add specific licensing review timeframes to enhance transparency and regulatory oversight.     R20-6-708 Table A

Colorado amended its regulations to require all pharmacy benefit managers operating in the state to register annually with the Division of Insurance and to clarify related compliance and enforcement procedures. The amendment updates the regulation’s effective date provisions and corresponding history section to reflect the revised implementation timeline.     3 CCR 702 Reg. 4-2-97 s 12

Illinois released a bulletin to provide guidance on the Prescription Drug Affordability Act, clarifying PBM reporting and fee obligations. PBMs must file annual reports on covered individuals and pay $15 per Illinois resident covered under administered plans, with enforcement temporarily deferred pending the enactment of HB 767, which further clarifies applicability, reporting requirements, and eligibility for credits or refunds. The bulletin specifies which plans are subject to the PDAA and provides instructions for submissions once HB 767 becomes law.     Bulletin 2025-20

Kentucky amended its regulations to enhance licensure, renewal, and oversight requirements for pharmacy benefit managers, including updated fees, financial responsibility standards, and reporting obligations. PBMs must pay a $10,000 registration fee (with certain exemptions), maintain evidence of financial responsibility of at least $1,000,000, and comply with clarified renewal procedures. Additionally, the regulation incorporates the updated Pharmacy Benefit Manager License Application form.     806 KAR 9:360

Kentucky issued a revised bulletin providing guidance on the implementation and enforcement of SB 188 for pharmacy benefit contracts. The bulletin clarifies ERISA preemption, confirming that minimum pharmacy reimbursement rates are enforceable while anti-steering provisions are preempted.     Bulletin 2025-03

Louisiana issued guidance on Act 474, establishing new reimbursement requirements for PBMs and health insurers contracting with PBMs. The law requires PBMs to use a reimbursement formula incorporating a prescription drug pricing benchmark (NADAC or an approved alternative), an adjustment factor to limit claim payment errors to 2% per drug, and a professional dispensing fee reflecting industry standards, with recommended markups and quarterly adjustments.     Advisory Letter 2025-05

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REGULATORY REPORTING REQUIREMENTS

Rhode Island summarized its 2026 annual and quarterly filing requirements for domestic and foreign health insurers. Insurers must follow the NAIC General Instructions, Health Insurers Checklist, and the Division’s Notes and Instructions, submitting required filings electronically to the Insurance Division (or Division of Taxation for premium taxes) by the specified due dates, while excluding unrelated items like annual statements, renewal fees, or retaliatory assessments.     Filing Requirements 2026 Health

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REPORTS - DATA CALLS & OTHER REPORTS

Colorado issued a revised bulletin requiring life, health, and private passenger auto insurers that do not use External Consumer Data and Information Sources (ECDIS), algorithms, or predictive models to submit annual attestations confirming non-use.     Bulletin B-10.001

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RISK-BASED CAPITAL

New York issued guidance for insurance companies on submitting Actuarial Opinions, Memoranda, and Risk-Based Capital Checklists, detailing filing requirements, deadlines, and submission procedures. Actuarial Opinions are due March 1, with checklists submitted by the Appointed Actuary via email for each legal entity, covering multiple regulations and specifying additional filings for MVA annuities, Universal Life with Secondary Guarantees, 2001 CSO Preferred Mortality Tables, and Variable Annuity Option Value Floor Reports.     AOM and Risk Based Capital Checklist