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Property & Casualty News March 2024
Property & Casualty News
March 2024
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!
ADJUSTERS
Kentucky adopted a regulation requiring a public adjuster to file for approval with the Commissioner any contract to be used to provide services to an insured. The regulation also mandates certain disclosure to be given to the insured. 806 KAR 9:400
AGENT / PRODUCER CONTINUING EDUCATION
New Hampshire's Insurance Commissioner reminds all Property and Casualty Producers of the requirement to complete a flood insurance course. This course is required even if the producer does not place flood insurance. Bulletin INS 24-006-AB
AGENT / PRODUCER LICENSING AND APPOINTMENT
Arkansas published a bulletin reminding companies of the requirement to file annual renewal appointments. The bulletin provides information about how to process renewals. Bulletin 2-2024
California published a notice reminding all licensees and applicants of the requirement to report any changes in background information within 30 days of the date the licensee or applicant learns of the change. Notice Dated March 5, 2024
AUTOMOBILE INSURANCE
Colorado adopted a rule to establish criteria for the notification of local law enforcement upon discovery that a person is attempting to obtain a certificate of title or register a stolen motor vehicle and for an insurance company or motor vehicle owner to obtain a Colorado certificate of title upon recovery of a stolen motor vehicle. 1 CCR 204-10, Rule 43
CLAIMS / CLAIMS ISSUES
Washington's Insurance Commissioner gave property insurance companies guidance regarding adjusting personal property claims and settlements due to the Gray and Oregon Road fires from 2023. Notice dated March 6, 2024
COMMERCIAL LINES INSURANCE
Vermont's Department of Financial Regulation requires all insurers issuing liability policies in Vermont to provide coverage for pollution. Limited exceptions may be allowed if authorized by the commissioner and described in the bulletin. Bulletin 111 (Revised)
CONFIDENTIALITY / PRIVACY
New Hampshire enacted legislation concerning a consumer Expectation of Privacy that applies to persons that conduct business and produce products or services targeted to residents of New Hampshire who process personal data of at least 35,000 unique consumers. It does not apply to entities or data subject to Title V of the Gramm-Leach-Bliley Act. SB 255
DISCRIMINATION
Connecticut published a bulletin reminding insurers that decisions based on analytical and computational technology (including AI Systems) must comply with all insurance laws and regulations. Domestic insurers must complete an AI Certification, due on September 1 of each year. The department states that the NAIC Principles of Artificial Intelligence is appropriate guidance. Bulletin MC-25
New Mexico added discrimination based on military status to the list of unlawful discriminatory practices. HB 302
ELECTRONIC TRANSACTIONS
South Carolina allows the posting of an insurance policy or endorsement by electronic means on the insurer's website if certain conditions are met. HB 3977
HOLDING COMPANIES
South Dakota updated its Insurance Holding Company law to include changes concerning the group capital calculation and the results of a liquidity stress test, among other items. HB 1059
LIABILITY INSURANCE
Kentucky adopted a regulation requiring that a school district must provide each certified district employee with liability insurance coverage of no less than $1 million for the protection of the employee against liability arising in the course of his or her employment. The regulation also establishes certain reporting duties for the school district. 702 KAR 3:330
Maine approved a bill clarifying liability under the Uncontrolled Hazardous Substance Site Law. The bill clarifies that each responsible party will be jointly and severally liable for all of the costs incurred by the state for the abatement, cleanup or mitigation. It also states that fees for assistance in submitting certain voluntary response action plans will be waived. HP 1328
MISCELLANEOUS
New Hampshire's Insurance Commissioner published a bulletin regarding the use of artificial intelligence systems by insurers. Bulletin INS 24-011-AB
PERSONAL LINES INSURANCE
Indiana enacted a legislation amending the probate code to require that an individual who acquires property upon an insured's death, succeeds to the rights and obligations of the insured under their property and casualty or liability policy for 60 days following the insured's death. The bill also requires disclosure be added to a transfer on death deed. HB 1034
New Hampshire adopted the Uniform Real Property Transfer on Death Act which allows individuals to transfer property to one or more beneficiaries at the transferors' death by using a transfer on death deed. HB 68
PROFESSIONAL LIABILITY INSURANCE
Alabama enacted legislation that provides civil and criminal immunity for death or damage to an embryo when providing or receiving services for in vitro fertilizations. SB 159
PROPERTY INSURANCE
New Mexico's Superintendent of Insurance reminds insurance companies that all repairs or replacement of residential property must be covered at the cost to repair or replace, without deduction for depreciation. Within 90 days all insurers must withdraw any previous forms citing a time limit for coverage for the cost to repair or replace and must file new forms excluding any time limit for coverage. Bulletin 2024-003 dated February 20, 2024
RATEMAKING
Michigan published a bulletin informing insurers that the practice of "price optimization" is not permitted in ratemaking under Michigan law. Michigan requires that property and casualty rates must not be excessive, inadequate, or unfairly discriminatory. Bulletin 2024-09-INS
REPORTS - DATA CALLS & OTHER REPORTS
Illinois published a bulletin notifying insurers that it will participate in the NAIC Property and Casualty Market Intelligence Data Call. Companies required to submit data will receive a letter from the NAIC. Company Bulletin 2024-07
Massachusetts issued a notice about the multi-state data call coordinated by the NAIC. The data call is intended to cover more than 80% of the US property insurance market. More information can be found on the NAIC website (naic.org). Notice of March 11, 2024
TITLE INSURANCE / AGENTS
Utah's Insurance Commissioner issued a bulletin advising title insurance producers that are affiliated with non-insurance businesses how the insurance department will apply insurance rules which may overlap with the Division of Real Estate rules. Bulletin 2024-2
WORKERS' COMPENSATION
California announced it now offers free, online educational courses for Workers' Compensation. Training includes courses on the Medical Treatment Utilization Schedule, a Qualified Medical Evaluator Module, and a Qualified Legal Report Writing Course. Notice dated February 28, 2024
California's Division of Workers Compensation announced that its San Jose office has moved to a new location at 224 Airport Parkway, Suite 600, San Jose, CA 95110. Notice dated February 16, 2024; Newsline No. 2024-13
Kentucky published notice reminding carriers of the annual audit and collections report. Reporting for CY 2023 will be due no later than June 30, 2024, and should be submitted via an Excel spreadsheet. Notice dated 2-12-2024
Nevada's Division of Industrial Relations, Workers' Compensation Section, published FAQs on COLAs for Permanent Total Disability (PTD) and Survivors' Benefits Claims. Notice dated February 2, 2024
Nevada's Insurance Commissioner approved NCCI's changes in workers' compensation annual voluntary insurance loss costs and assigned-risk market rates. Notice dated March 1, 2024
Texas Division of Workers' Compensation adjusted the billing methodology and reimbursement rates for certain specific services provided on or after June 1, 2024. 28 TAC s 134.209
Wyoming passed a law that authorizes consideration of specified investment earnings for determining rates under the worker's compensation program. HB 72
Newsletter
Property & Casualty News April 2024
Property & Casualty News
April 2024
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!
ARTIFICIAL INTELLIGENCE
Illinois published a bulletin reminding companies that all existing laws and regulations, including unfair trade practices and unfair discrimination, apply to actions involving artificial intelligence systems. The bill explains new regulations requiring insurers to develop and maintain a written program for the use of artificial intelligence to avoid adverse consumer actions. Company Bulletin 2024-08
Pennsylvania's Insurance Commissioner issued a notice explaining expectations of insurers regarding the development, acquisition, and use of certain Artificial Intelligence technologies. Notice 2024-04
Rhode Island's Superintendent of Insurance distributed a bulletin to all insurers with Certificates of Authority asking them to comply with the Department's expectations regarding predictive models, risk management, internal controls, and third-party Artificial Intelligence systems. Bulletin 2024-03
AUTOMOBILE INSURANCE
Alabama established the state's Automobile Insurance Plan, which is intended to help apportion the cost of high-risk motor vehicle policies. SB 47
Idaho enacted a bill amending the Motor Vehicle definitions. It creates a new definition for Service-Only Facility, meaning a dealership location where motor vehicle service only is performed. HB 640
North Carolina's Rate Bureau received approval of changes applicable to Personal Auto Policy policies on and after January 1, 2025. These changes include revised liability base rates and increased limit factors. Circular Letter A-24-1
Oklahoma's Insurance Commissioner informed producers and carriers of a change in a Farm Driving Permit. Any person who is less than 17 years old but at least 14 years old and who resides on a farm or is employed on a farm may operate a Class D motor vehicle. Insurers may provide coverage but are not required to do so. Bulletin 2024-02
CAPTIVES
Tennessee amended its Captive Insurance Act to include definition and provisions for an Agency Captive Insurance Company and therefore modified the definition of Captive Insurance Company. SB 2024
CERTIFICATES OF INSURANCE
Georgia published a bulletin providing answers to frequently asked questions regarding certificates of insurance. Bulletin 24-EX-4
COMMERCIAL LINES INSURANCE
Arizona enacted legislation to revise the minimum commercial vehicle coverage amounts, including a minimum for transportation network company (TNC) coverage of $1 million per incident when a passenger is present. HB 2729
CYBERSECURITY
Illinois published a bulletin notifying insurers of the Insurance Data Security Law, which became effective 01/01/2024. The bulletin explains the mandatory initial notification of a cybersecurity event and the continuing obligation to update. Beginning 04/15/2025, there will be an annual certification of compliance required. Bulletin 2024-10
DEPARTMENT OF INSURANCE
Idaho enacted legislation amending provisions relating to administrative rules. Changes include allowing the legislature to review and reject materials incorporated by reference. Amendments also require that incorporated materials must be easily accessible on the agency's website. HB 563
FILINGS: PROPERTY / CASUALTY
Iowa adopted revised regulations making technical and other updates the form and rate filing requirements. The new chapter also sets out the requirements for the Iowa Fair Access to Insurance Requirements (FAIR) Plan. 191-20.1
FRAUD / ANTI-FRAUD
Delaware published a reissued bulletin regarding the Insurance Fraud Reporting Form. Insurers are reminded of the state's mandatory reporting requirements. Domestic-Foreign Insurers Bulletin 15 (Reissued)
MISCELLANEOUS
West Virginia passed a law allowing an unlicensed person who refers a customer to seek an opinion or advice on purchasing insurance to accept a one-time nominal fee of $100 or less. HB 5057; 33-11A-7
NOTICE TO INSUREDS
The Texas Insurance Commissioner adopted amendments to the consumer rights notices for personal automobile, homeowners, dwelling and renters insurance. These notices are given by the insurer to the policyholder when the policy is issued. 28 TAC s 5.9970 and 5.9971
OMNIBUS LEGISLATION
Indiana adopted a bill enacting numerous measures, including changes to the oversight of continuing education courses. It also removes the requirement for an alien or foreign insurer to annually file with the department a statement of its assets and liabilities. HB 1332
PERSONAL LINES INSURANCE
Connecticut published notice to advise insurers of the Department's position concerning the extent of roof damage needed to support underwriting action and the acceptable use of aerial imagery technology to evaluate such damage. The notice also reminds insurers of the need to provide an insured of at least 60 days advance notice of nonrenewal. Notice Dated 3-19-2024
Minnesota published a bulletin to all companies writing homeowners insurance. The bulletin notifies companies of the requirements for completing zip code reporting and provides for electronic submission. Administrative Bulletin 2024-1
Virginia passed a law requiring optional coverage to be offered with a new or renewal homeowner's policy or stand-alone policy that covers scheduled personal property. The optional insurance provides coverage for the diminution in value of any scheduled personal property, if the schedule provides for repair of the property. HB 1257; 38.2-2120
PROFESSIONAL LIABILITY INSURANCE
Washington passed the Uniform Telehealth Act which sets out when telehealth services may be provided and provides for a patient-practitioner relationship to be established through telehealth. SB 5481
TITLE INSURANCE / AGENTS
Maryland issued a bulletin providing notification of amendments affecting title insurance during the legislative session. The bulletin addresses notification and reporting duties as well as examples of possible violations. Bulletin 24-7
TRADE PRACTICES
Maine enacted legislation requiring telephone solicitors, prior to commencing a sales call, to use the reassigned numbers database to verify that a consumer's telephone number has not been reassigned. HP 1433
UNCLAIMED PROPERTY
Idaho approved a bill revising its unclaimed property act. Changes are intended to clarify certain presumptions, provide definitions and guidelines for policies and procedures, including reporting and notice. HB 471
WORKERS' COMPENSATION
California's Division of Workers Compensation updated the requirements for a Qualified Medical Evaluator (QME), including requirements for additional training, including anti-bias content. Other updates include provisions for QMEs who are unavailable for additional evaluations due to caseload. T. 8 s. 1, et seq
Kentucky enacted amendments to its Workers' Compensation law including new definitions of physician and an update to the calculation of unemployment benefits. HB 401
New Jersey's Compensation Rating and Inspection Bureau issued a circular letter updating the data for Residual Market policies and policy expirations scheduled for July 2024. This information is published monthly to facilitate the depopulation of the Plan. Circular Letter 2064
Oregon passed a law creating the crime of fraudulent misrepresentation. This occurs when an employer fraudulently misrepresents information to an insurer or state entity with intent to reduce workers' compensation premiums. SB 1580
South Carolina's Workers' Compensation Commission approved changes to the Medical Services Provider Manual (MSPM) for 2024. Advisory Notice dated March 29, 2024
Tennessee amended its Pharmacy Benefit Manager (PBM) rule regarding required actions during and after an initial appeal. Rule 0780-1-95-.02
Virginia added reporting requirements in its Pharmacy Benefit Manager law. HB 1402
Virginia's Workers' Compensation Commission updated the workers' compensation mileage reimbursement rate, weekly and maximum benefits chart. WC Benefits Chart dated March 28, 2024
Washington reduced the number of days (from 14 days to 7 days) that a worker's temporary total disability must continue to receive worker's compensation benefits for the day of the injury and the first three days following the injury. HB 1927
Wyoming's Department of Workforce Services published the updated statewide average monthly wage for the second quarter of 2024. Statewide Average Monthly Wage dated April 1, 2024
Newsletter
Life and Health News November 2025
Life and Health News
November 2025
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!
AFFORDABLE CARE ACT
Illinois amended its Administrative Code to transition to a full State-based Exchange for Plan Year 2026, affecting health insurers and consumer assistance personnel such as Navigators, In-Person Counselors, and Certified Application Counselors. The updates clarify certification and renewal requirements, eliminate fingerprinting and Illinois business location mandates, and establish DOI-approved training and continuing education standards. A new section, 4515.110, introduces a state-provided education curriculum covering insurance principles, QHP options, affordability programs, Marketplace and Medicaid policies, and outreach skills. 50 Ill. Adm. Code 4515.10
AGENT / PRODUCER LICENSING AND APPOINTMENT
California adopted new amendments removing the 20-hour pre-licensing coursework requirement for license applicants and authorizing fees for completing the 12-hour ethics course certification. The changes conform updates across related sections to align definitions, licensing processes, and education provisions for agents, service contract providers, and other licensees. AB 943
New Mexico released a bulletin detailing the 2026 Agent Appointment Renewal process, requiring all insurers to complete renewals electronically via NIPR. Billing begins January 5, 2026, with payments due by April 30, 2026, and all agent terminations must be processed by December 26, 2025. 2026 Appointment Renewal Notice
Oklahoma issued its 2025 Appointment Renewal Notification to guide insurers on updating Producer Licensing/Appointment contact information and completing electronic appointment renewals via NIPR. Renewal invoices will be available from November 25 through December 31, 2025, and all payments must be submitted by 4 p.m. CST on December 31 to avoid termination of appointments. Insurers must ensure contact information is current, submit terminations by November 14, and resolve disputes with NIPR by November 12. 2025 Appointment Renewal Notification
CYBERSECURITY
California amended its Civil Code to improve the timeliness of data breach notifications. Businesses must now notify affected individuals and authorities within 30 calendar days of discovering a breach, with allowances for law enforcement delays or system restoration. For breaches affecting over 500 California residents, a sample copy of the notification must be submitted electronically to the Attorney General within 15 days. SB 446
California issued guidance on mandatory reporting of personal information breaches for all insurers, producers, support organizations, and related entities. The notice reinforces compliance with the Insurance Information and Privacy Protection Act (IIPPA), requiring timely reporting of breaches involving unencrypted data. Insurers must provide the DOI with copies of breach notifications sent to the Attorney General, sample consumer notifications (excluding personal data), and report breaches affecting affiliates or service providers. Notice Dated 9/30/25
DENTAL INSURANCE
California enacted new legislation to regulate payment methods to dental providers, effective April 1, 2026. The law requires non-fee-based payments as the default and mandates affirmative consent from providers before using fee-based payment methods, which can be revoked at any time. These provisions apply to health plan contracts and policies issued, amended, or renewed on or after that date. SB 386
DISASTER / CATASTROPHIC EVENT
Arizona published a bulletin in response to severe flooding in Gila County following the Governor’s September 27, 2025, emergency declaration. The bulletin urges insurers to provide at least 90 days of relief to affected policyholders, including grace periods, payment flexibility, and waived fees, to ensure continuity of coverage and claims processing. Bulletin 2025-09
DISCRIMINATION
Colorado published a bulletin for life insurers clarifying the quantitative testing reporting requirement under section 5.A.11 of Regulation 10-1-1. The bulletin waives this reporting for annual reports due December 1, 2025, pending finalization of testing rules, but confirms that all other provisions of the regulation remain enforceable. Insurers are advised to comply with the requirement in future reports once the rules are adopted and may contact the Division for guidance. Revised Bulletin B-10.004
Texas released a bulletin to implement SB 1238, prohibiting insurers, including HMOs, from discriminating against widowed individuals. Effective for policies issued, delivered, or renewed on or after September 1, 2025, insurers must ensure coverage, rates, and options treat widowed individuals equally to married individuals. Bulletin B-0014-25
FRAUD / ANTI-FRAUD
Louisiana issued a directive requiring all authorized insurers and HMOs to file annual and supplemental anti-fraud plan reports electronically. Reports must include detailed data on claims, suspicious claims, fraud investigations, recoveries, and resources allocated, and be submitted by April 1 each year. Directive 228
GROUP INSURANCE
California updated its rules for student health insurance coverage, effective July 1, 2026. The amendment allows students to terminate coverage midyear if they graduate, take a leave of absence, or are no longer enrolled, with termination effective within the same or following calendar month. It also requires institutions to grant waivers for students with minimum essential coverage, prohibits related fees, with penalties up to $5,000 per violation or $10,000 for willful violations. AB 594
HEALTH INSURANCE - COMPREHENSIVE
California is now reducing out-of-pocket costs for insulin and eliminating coverage barriers. Beginning January 1, 2026, large group health plans and policies, and beginning January 1, 2027, individual and small group plans, may not impose cost-sharing over $35 for a 30-day supply of insulin. The bill also prohibits step therapy requirements for insulin and requires large group plans to cover at least one insulin product for each drug type in all forms and concentrations on their formularies. SB 40
California released a bulletin implementing AB 144 to ensure continued access to preventive care, including federally or state-recommended immunizations as of January 1, 2025. Health insurers must cover preventive services with USPSTF “A” or “B” ratings, ACIP recommendations, or HRSA guidelines without cost-sharing, including public health emergency-related immunizations, and implement any CDPH updates within 15 business days. Coverage includes childhood evaluations, immunizations, and laboratory services, and specific vaccines such as COVID-19, influenza, and RSV for eligible populations must be covered starting October 8, 2025, even if used off-label under FDA guidelines. Bulletin 2025-14
MISCELLANEOUS
California announced the launch of Sircon Online “Additional State Service Requests”, expanding electronic submission and fee payment for 10 specific licensing and bond forms. This service builds on the DOI’s 2019 transition to Sircon and aims to streamline filings for insurers, agents, brokers, and education providers. Notice Dated 10/17/25
Colorado issued a bulletin addressing the impact of the federal government shutdown on approximately 57,000 federal employees and their families. The Division urges carriers to prevent coverage lapses by offering a 30-day premium grace period, waiving late fees, providing flexible payment options, and clearly communicating support measures to affected policyholders. Bulletin B-6.05
Connecticut directs all insurers to provide federal employees affected by the government shutdown with at least a 60-day grace period or flexible payment options for premiums. The released bulletin applies to life, health, auto, property, casualty, and other insurance lines and emphasizes maintaining coverage without forgiving premiums or altering policy terms. Bulletin IC-46
Maryland urges insurers and premium finance companies to prevent policy cancellations during the federal government shutdown by deferring payments, extending grace periods, accepting partial payments, and waiving late fees. The published guidance applies to all lines of life, health, property, and casualty insurance and allows insurers to request a permitted accounting practice to admit premium receivables in line with grace periods. The Department emphasizes proactive measures to maintain coverage for residents and businesses facing financial hardship. Bulletin 25-16
Nevada requests insurance carriers assist policyholders impacted by the federal government shutdown by providing premium grace periods, waiving or delaying late fees, and offering flexible payment options to ensure continuous coverage. Bulletin 25-003
Oregon requests insurers and other regulated entities to assist policyholders affected by the federal government shutdown. The released guidance recommends offering at least a 30-day grace period for premiums, flexible payment and fee options, refraining from cancellations or non-renewals, and proactively communicating support measures to affected individuals. Bulletin DFR 2025-8
MISCELLANEOUS HEALTH / ACCIDENT
Arkansas issued a bulletin updating rules for Short-Term, Limited Duration Insurance (STLDI) plans. The bulletin permits authorized issuers to offer STLDI plans with terms under 12 months and renewals up to 36 months, consistent with Arkansas law and recent federal guidance. It reiterates requirements for mandated benefits, disclosure notices, and clear labeling, emphasizing that STLDI plans do not meet ACA standards and advising consumers to consult licensed producers before purchasing coverage. Bulletin 14-2025
Arizona released a bulletin reminding licensed producers to comply with state laws when soliciting and selling health insurance. The bulletin addresses issues such as poor recordkeeping, unauthorized policy sales, and enrolling consumers without consent, urging strict compliance during open enrollment. Violations may result in administrative actions, including license suspension or revocation. Bulletin 2025-07 (INS)
Michigan released updated guidance on short-term limited duration (STLD) insurance and fixed indemnity excepted benefits, reflecting that the federal government no longer enforces certain notice and STLD requirements. Michigan law still limits STLD policies to 185 days per year, exempts them from covering preexisting conditions, and excludes ACA protections, while DIFS continues to review forms and rates. Bulletin 2025-22-INS
OMNIBUS LEGISLATION
California adopted numerous amendments to sections of the Insurance Code. Key updates include clarifying claim reimbursement timelines, expanding blanket insurance eligibility to volunteers, modernizing advertising and licensing provisions with gender-neutral language, and refining qualifications for agents and fraternal benefit society representatives. Additional changes address investment limits for the State Compensation Insurance Fund, service contract administrator definitions, bail licensing, and updates to the Insurance Frauds Prevention Act and securities-related provisions. AB 487
PHARMACY BENEFIT MANAGERS
California enacted reforms to pharmacy benefits and pharmacy benefit managers (PBMs), effective January 1, 2026. The law prohibits plans and insurers from charging enrollees or insureds more than the actual plan-paid cost for prescription drugs and requires transparent cost-sharing. PBMs are assigned fiduciary duties, prohibited from discriminating against nonaffiliated pharmacies, and must use passthrough pricing models with all manufacturer rebates directed to payers to offset costs for plan participants. The law also bans spread pricing, restricts retroactive claim adjustments, ensures nonaffiliated pharmacies can offer delivery, and sets enforcement provisions and penalties for noncompliance. SB 41
New Mexico updated its licensing and reporting requirements for Pharmacy Benefit Managers (PBMs). PBMs must now file new and renewal license applications through the Company Licensing Bureau, pay $500 renewal and $200 annual report fees by March 1, and submit annual compliance reports via SERFF by June 1. Required filings include attestations, audits, contracts, grievance reports, and website information, with confidentiality requests available. Bulletin 2025-011
North Carolina adopted new PBM regulations, enhancing oversight, financial responsibility, and operational standards. The rules cover licensing, fees, financial statements, claim processing, and general administration, including requirements for governing bodies, internal policies, audits, and timely reporting of claim statuses. Initial PBM licenses cost $2,000, annual renewals $1,500, and PBMs must submit audited financial statements and maintain comprehensive management systems to ensure compliance. 11 NCAC 24 .0101
PRE-NEED CONTRACTS
Arkansas adopted amendments to its rules regarding Funeral Expense Insurance, increasing the maximum coverage limit from $15,000 to $25,000. The amendments also update statutory references and revise the Definitions and General Requirements Provisions. 23 CAR s 91-101
REGULATORY REPORTING REQUIREMENTS
Arkansas announced the Draft Version 9.0.2025 of the Data Submission Guide (DSG) for the Arkansas Healthcare Transparency Initiative. The update enhances data clarity for the All-Payer Claims Database by adding denied claims, non-claims payment data, and pharmacy rebate data, while restructuring the guide into three parts for easier use. Bulletin 12-2025
Arkansas issued a bulletin to clarify the definition of “insured employees” under Act 651 of 2025 for group accident and health insurance reporting requirements. The Department interprets the Arkansas Code to require healthcare insurers to provide premium, claim, and enrollment reports if a policyholder employed an average of more than fifty total employees in the prior calendar year, regardless of the number of insured individuals. The bulletin reinforces compliance with this interpretation and provides contact information for related inquiries. Bulletin 13-2025
Maryland released a bulletin updating the Reporting Form for Adverse Decisions and Grievances, effective October 1, 2025, to improve transparency. Carriers must disclose the use of AI in adverse decisions and report zip code-level data identifying the top five areas by adverse/grievance ratios. The updated form must be used for the October-December 2025 report, due January 30, 2026. Bulletin 25-15
Wyoming requires all licensed insurers to submit 2025 premium tax filings and payments through the NAIC OPTins system, effective for filings due March 1, 2026. Paper submissions are no longer accepted, and insurers may consolidate the first three quarterly filings into a single submission to reduce fees. Memorandum 10-2025
STOP LOSS
Arizona issued a bulletin clarifying the regulatory treatment of stop loss insurance products. The bulletin explains that stop loss coverage, typically linked to self-funded employer health plans, is not regulated as group health insurance and must not create a direct relationship between the insurer and individual employees. It further outlines prohibited policy provisions that could transform stop loss coverage into health insurance and emphasizes compliance with Arizona law. Bulletin 2025-08 (INS)
TRADE PRACTICES
Idaho released a bulletin addressing unfair trade practices in marketing Medicare-related insurance products, including Medicare Advantage and Supplement plans. It directs carriers to ensure enrollment applications are accessible, prohibits discouraging sales or altering commissions mid-year, and requires commissions built into rate development to be honored. The bulletin emphasizes carriers’ and producers’ legal and ethical duties to act in consumers’ best interests and warns that violations may result in enforcement. Bulletin 25-06
UNCLAIMED PROPERTY
Arkansas adopted new rules to establish consistent procedures for administering the state’s Unclaimed Property Program. The rules outline requirements for holders, including due diligence, reporting, delivery, and confidentiality obligations, as well as processes for claims, finder agreements, and contract auditors. 18 CAR s 1-101
California amended the Unclaimed Property Law to address digital financial assets, establishing when and how such assets escheat to the state. The law defines key terms and requires holders to transfer unclaimed digital assets, along with any associated keys, to the Controller or a designated custodian within 30 days of reporting. Digital assets unclaimed for three years are subject to escheat, with provisions for notices to owners, handling of partial keys, conversion to fiat currency, and entitlement of claimants to the asset or proceeds, while the Controller may designate custodians for safekeeping. SB 822
Newsletter
Property & Casualty News February 2024
Property & Casualty News
February 2024
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!
AUTOMOBILE INSURANCE
Michigan's Department of Insurance and Financial Services, Office of General Counsel, published a bulletin regarding payment and billing guidance for No-Fault Automobile insurers and health care providers. Bulletin 2024-06-INS
Virginia's Automobile Insurance Plan manual of rules and rates has been revised by approving the submission made by the Automobile Insurance Plans Service. The amendments apply to new and renewal policies effective on and after May 1, 2024. Administrative Order 12179
CANCELLATION / NON-RENEWAL / PREMIUM OR COVERAGE
Georgia issued a bulletin reminding carriers of the requirements and prohibitions concerning non-renewals. Insurers nonrenewing a policy must provide written notice, mailed or personally delivered, at least 30 days prior to the effective date of nonrenewal. 60 days after the effective date of the policy/renewal date, an insurer can only cancel for non-payment of premium, discovery of fraud, substantially increased hazard or violation of the material terms of the policy. Any notice of a reduction in coverage must be in a separate document and include a title in all capital letters of at least 12-point type. Bulletin 24-EX-2
CLAIMS / CLAIMS ISSUES
Colorado issued a bulletin providing guidance to insurers issuing homeowner policies in the state. The bulletin addresses the handling of claims as a result of the Marshall and Middle Fork Fires. Insurers are asked to toll or temporarily suspend time limits applicable to claims. Companies should have a process in place no later than 02/16/24. Failure to provide reasonable accommodation may be viewed as non-compliant with good faith practices. B-5.48
Florida removed obsolete language from a regulation, penalizing insurers who regularly fail to appear at mediation conferences. 69O-166.031
Montana's Commissioner of Securities and Insurance issued an Advisory Memorandum providing claims settlement guidance to insurers with regard to providing advanced payment (prior to final settlement) to a victim of an automobile accident for any damages for which liability is reasonably clear, including medical expense, lost wages and costs of acquiring medical records. Advisory Memorandum dated January 26, 2024
CYBERSECURITY
New York's Department of Financial Services notified Chief Information Security Officers of regulated institutions of the dangers in allowing users to reset passwords themselves. The Department recommends multifactor authentication to increase security. Letter dated January 12, 2024
DEPARTMENT OF INSURANCE
Arkansas adopted new rules establishing formal and informal procedures governing the activities of the insurance department. Rule 125
DISASTER PREPAREDNESS
New York passed a law spelling out standards for prompt investigation and settlement of claims for loss of or damage to real property, personal property and other liabilities when the Governor declares a disaster emergency or when the President issues a major disaster or emergency declaration. AB 2078; Ins. Law s 2618
ELECTRONIC TRANSACTIONS
South Carolina passed a law allowing standard property and casualty policies or endorsements that do not contain personally identifiable information to be posted on the insurer's website. Compliance requirements are provided. HB 3977; 38-55-730
HOLDING COMPANIES
Massachusetts amended rules to implement recent changes to the Massachusetts Insurance Holding Company System. 211 CMR 7.02
MISCELLANEOUS PROPERTY / CASUALTY
New Mexico's Superintendent of Insurance issued an emergency rule that applies to all property and casualty insurers dealing with notification requirements for discontinuing insurance products. All P&C carriers are to provide at least 30 days’ notice to the Superintendent prior to the effective date of discontinuance. Emergency 13.8.7.1 NMAC
PROPERTY INSURANCE
California published its annual notice of significant laws pertaining to residential property insurance policies. Topics include claims and coverage, valuation and appraisals and wildfire risks. Notice Dated January 5, 2024
Illinois amended its Home Property Insurance statute to prohibit an insurer from refusing to issue or renew, cancel, charge, or impose an increased premium based solely on owning any dog of a specific breed or mix of breeds. Insurers may consider whether an individual dog is dangerous or vicious under the Animal Control Act. HB 1049
REGULATORY REPORTING REQUIREMENTS
Federal Financial Crimes Enforcement Network (FinCEN) issued an alert to financial institutions related to the financing of Israeli extremist settler violence against Palestinians in the West Bank. This alert provides select red flags to assist in identifying and reporting suspicious activity that finances such violence. FIN-2024-Alert001 February 1, 2024
Utah's Insurance Commissioner reminds insurers that issue policies with motor vehicle liability coverage, uninsured motorist coverage, underinsured motorist coverage or personal injury coverage they must regularly report those policies to Insure-Rite. Bulletin 2024-1
REPORTS - DATA CALLS & OTHER REPORTS
Maryland published a bulletin notifying all insurers, and similar organizations, of the requirement to provide certain contact information by 04/15/24. Information must be submitted electronically and include contact information in the event of a disaster or catastrophic event. Instructions on reporting are included in the bulletin. Bulletin 24-2
North Carolina's Insurance Department notified insurers of the semi-annual Data Call that applies to companies that issued Consent to Rate policies during the period 07/01/23 - 12/31/23 covering loss to nonfleet private passenger motor vehicle physical damage and homeowners’ residential property with not more than four housing units. The data must be submitted by March 15, 2024. Bulletin 24-B-02
SURPLUS LINES
Connecticut issued a bulletin notifying insurers of the requirement for foreign eligible surplus lines insurer to file financial statements. Companies are further reminded of the disclosure required on the cover of each policy, notifying the insured that it is a surplus lines policy. Bulletin FS-4SL-23
TITLE INSURANCE / AGENTS
Rhode Island released a summary of annual and quarterly filing requirements for domestic and foreign title insurance companies. Please note that the state's instructions for companies to file with the NAIC are included in a checklist. The NAIC will not be sending their own checklist this year. Special Reporting Requirements 2024
TRADE PRACTICES
Alaska reminded insurers of their duty to comply with all applicable laws or regulations when its use of artificial intelligence (AI) impacts consumers of the state. Laws involving use of AI include the unfair trade practices act and the unfair claims settlement practices act. The bulletin reiterates the risks the department sees in the use of AI and notifies insurers of the requirement to establish an AI Systems Program to provide oversight. The department will be performing inquiries and examination to ensure compliance. Bulletin B 24-01
District of Columbia amended the "Protecting Consumers from Unjust Debt Collection Practices Technical Clarification Emergency Act of 2024." The Act prohibits any creditor or debt collector from harassing any person in an attempt to collect a debt including by visiting his or her household or by publicizing the debt. B-662
WORKERS' COMPENSATION
Alabama announced the 2024 mileage reimbursement rates for workers compensation recipients. WC Notice of Mileage
Kansas issued an informational notice explaining the manner in which private reimbursement mileage rates will be set and announcing the state rates established as of 01/01/24. Informational Circular 24-A-006
Louisiana published notice that it has approved the annual loss cost filing of NCCI for a 9% reduction in workers compensation rates, effective 5-2024. Workers’ Compensation rates have fallen consistently at a rate of -66% over the past 20 years. Notice Dated 12-28-2023
Maryland's Insurance Commissioner issued a bulletin clarifying that in Apprenticeship Programs the age of the worker does not impact Workers Compensation Rates. Bulletin 24-3
Nevada Division of Industrial Relations, Workers Compensation Section notified insurers, Third-Party Administrators and Health Care Providers of a change in the 2024 Medical Fee Schedule due to the reported annual CPI for Medical Care. 2024 Nevada Medical Fee Schedule CPI Change
New Hampshire's Department of Labor increased the standard mileage reimbursement rate for eligible Workers' Compensation travel expenses to 67 cents per mile. The new rate applies to expenses incurred on and after January 1, 2024. DOL Notice dated January 2024
Pennsylvania's Insurance Department announced it is conducting its annual Workers' Compensation Special Schedule "W" data call. The information is due before April 15, 2024. 2023 Special Schedule "W" Letter - Notice dated February 6, 2024
Wisconsin's Department of Workforce Development issued its 2023 Workers' Compensation Supplemental Benefit Reimbursement Assessment. Insurance carriers are requested to pay the assessment invoice immediately and unpaid balances after 30 days will accrue interest. Insurance Letter 542
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