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Life and Health News October 2025
Life and Health News
October 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
Georgia issued updated guidance following the federal court injunction in City of Columbus v. Kennedy, which blocks implementation of the federal Actuarial Value (AV) policy for Plan Year 2026. As a result, some Qualified Health Plans (QHPs) filed for Georgia Access may now be non-compliant. The DOI is allowing re-filing of only those plans it identifies as affected, with changes limited to restoring AV compliance. Bulletin 25-EX-2
AGENT / PRODUCER LICENSING AND APPOINTMENT
New Mexico now requires all name change requests for licensed producers (individuals and business entities) to be submitted online via NIPR.com, discontinuing acceptance of paper forms. A $50 penalty fee applies if changes are reported more than 30 days after the legal name change, and payment must be sent by check or money order with proper memo information. Notice Dated 9/4/25
ARTIFICIAL INTELLIGENCE
Colorado is delaying the implementation of SB 24-205, from February 1, 2026, to June 30, 2026, which establishes consumer protections against algorithmic discrimination in AI systems. The postponement affects compliance and enforcement timelines, including deceptive trade practice provision. SB 4
CAPTIVES
Alabama extended its temporary moratorium on the licensing or registration of new captive insurers and domestic risk retention groups until June 30, 2026. The extension amends Bulletin 2025-01 and directs affected entities not to submit applications or fees during the moratorium period. Applications submitted before March 1, 2025, remain under review and are not impacted. Bulletin 2025-05
CREDIT INSURANCE
Illinois amended its regulations to align credit insurance refund calculations with Department of Insurance rules, now requiring refunds to be computed according to 50 Ill. Adm. Code 1053.10 instead of the previous “at least as favorable” actuarial method. 38 Ill. Adm. Code 110.170
EXCEPTED BENEFITS
North Carolina confirmed that the federal definition of short-term, limited duration (STLD) insurance in 45 C.F.R. 144.103 remains the standard for the state. No STLD plans may be offered unless they comply with this current federal definition, and existing policies issued under prior rules remain valid. Bulletin 25-B-11
HEALTH INSURANCE - COMPREHENSIVE
Arizona is expanding access to COVID-19 vaccinations following the FDA’s approval of updated vaccine formulations limited to high-risk populations. The order directs state health agencies and the Board of Pharmacy to ensure vaccine availability and coverage, allowing providers to administer vaccines based on scientific evidence and clinical judgment. Executive Order 2025-12
California's Department of Managed Health Care issued guidance on AB 144, requiring full-service commercial and Medi-Cal managed care plans to cover preventive services—including COVID-19, RSV, and influenza immunizations—without cost-sharing or utilization management. Coverage must extend to out-of-network and off-label immunizations aligned with CDPH guidance and remain in effect for the entire plan year. DMHC APL 25-015
Colorado adopted an emergency regulation to require health insurance carriers to cover 2025–2026 COVID-19 vaccines as preventive services without cost-sharing. The rules apply to individual, small group, large group, student, and managed care plans, aligning with ACIP and CDPHE guidance, and encourage third-party administrators of self-funded plans to comply for uniform access. The regulation includes provisions for definitions, enforcement, severability, and incorporation by reference. Emergency Reg. 25-E-04
Connecticut confirms that COVID-19 vaccines remain mandatorily covered under state insurance law as part of required immunization benefits. All individual and group health policies must cover vaccines recommended by leading medical organizations, including ACIP, without cost-sharing. Even if ACIP changes its recommendation, vaccine coverage remains mandatory, though insurers may exclude cost-free provider consultations in that case. Bulletin HC-133
District of Columbia clarified that health carriers in the individual, small, and large group markets must continue covering all ACIP-recommended vaccines, including age-appropriate, FDA-approved COVID-19 vaccines, without cost-sharing or restrictive utilization management. Coverage expectations also extend to any vaccines designated by the DC Department of Health via public notice. These requirements do not apply to Medicare, self-funded plans, or limited scope and excepted benefit plans. Bulletin 25-IB-003-09/17
Hawaii issued a memorandum directing all authorized health insurers to continue covering COVID-19 vaccinations for individuals aged six months and older without cost-sharing or utilization management, including for off-label uses. Insurers are also expected to coordinate with providers and the Department of Health to ensure adequate vaccine supply and equitable access, especially for high-risk populations. Clear communication with members and uninterrupted vaccine access are emphasized, with further guidance possible as the situation evolves. Bulletin 25-EX-2
Illinois' Governor launched the Statewide Vaccine Access Initiative to ensure broad, equitable access to vaccines amid federal disruptions. Led by IDPH, the initiative authorizes expanded vaccine administration, prioritizes underserved populations, mandates insurer coverage without cost-sharing, and enhances outreach through partnerships and accessible guidance. Executive Order 2025-04
Louisiana clarified that health insurers must cover biomarker testing when it demonstrates clinical utility. Insurers cannot impose additional criteria beyond those specified in the law and must use the least restrictive standard when multiple evidence categories apply. The released bulletin emphasizes minimizing care disruptions and ensuring clear, compliant medical policy language. Bulletin 2025-05
Maine released a bulletin requiring health insurance carriers to cover COVID-19 and other immunizations recommended by leading medical academies or authorized by the FDA, without cost-sharing or prior authorization. This includes both the vaccine and its administration, with limited network restrictions permitted. Administrators of self-insured and level-funded plans must notify plan sponsors of these mandates and encourage compliance. Bulletin 486
Massachusetts issued joint guidance from the Division of Insurance and Department of Public Health requiring insured health plans to cover all vaccines and their administration without cost-sharing or utilization management, as long as they follow DPH immunization guidelines. Carriers must update plan documents and online resources to reflect this, and while formulary or network restrictions are allowed, access must still be guaranteed for each recommended vaccine. Self-funded plans are encouraged to follow the same standards. Bulletin 2025-03
Michigan now requires state-regulated health insurance plans, including Medicaid, to cover COVID-19 vaccines and directing agencies like MDHHS, DIFS, and LARA to remove access barriers and promote vaccination. The released directive emphasizes the safety and effectiveness of COVID-19 vaccines and mandates cross-agency coordination to ensure equitable access for all residents. Executive Directive 2025-07
New Jersey issued a bulletin requiring health insurance carriers to continue covering COVID-19 vaccines and their administration without cost-sharing, consistent with state law and public health guidance. Carriers must ensure benefit materials are updated and accessible and encourage non-regulated plans to align with the same standards. Bulletin 25-EX-2
New Mexico requires health insurers and HMOs offering major medical or comprehensive coverage to maintain consistent immunization coverage for the 2025 and 2026 plan years based on the ACIP guidance in effect at the time of rate approval. Changes to immunization coverage reflecting updated ACIP recommendations will only take effect starting with the 2027 plan year. Bulletin 2025-009
Oregon released a bulletin reinforcing that all health benefit plans, including grandfathered ones, must cover FDA-approved COVID-19 vaccines and their administration without cost-sharing or network restrictions. This guidance supports access to vaccines without financial barriers and aligns with the newly formed West Coast Health Alliance’s coordinated immunization efforts. Bulletin 2025-6
Rhode Island mandates that licensed health care entities provide coverage for all COVID-19 vaccines and their administration costs without cost-sharing. This requirement applies to insured plans and encourages administrators of self-funded plans to promote alignment with these provisions, ensuring members face no barriers to accessing COVID-19 vaccinations. Health Bulletin 2025-02
Wisconsin issued a bulletin requiring health insurers and governmental self-funded plans to cover COVID-19 vaccines and their administration without cost-sharing for all eligible policyholders, based on a standing medical order. The bulletin warns that selectively providing cost-free coverage may be considered unfair discrimination unless justified by actuarial or medical evidence. Bulletin Dated 9/16/25
HEALTH INSURANCE / HEALTH RATES
Maine approved average health insurance premium increases for 2026 of 23.9% in the individual market and 17.5% in the small group market, citing rising medical and drug costs and federal policy uncertainty. Notice Dated 9/4/25
Maryland approved 2026 health insurance premium rates with an average increase of 13.4% for individual ACA plans and 4.9% for small group plans, both lower than insurers initially requested. A new state subsidy program will offset the loss of enhanced federal tax credits for low- to middle-income residents. Dental plan premiums will decrease by an average of 1.4%. Notice Dated 9/19/25
HOLDING COMPANIES
Vermont updated its provisions for Insurance Holding Company Systems, including new rules for group capital calculations and electronic filing requirements. The lead state commissioner may exempt certain companies from full filings based on specific criteria and can require filings if financial concerns arise. Regulation 71-2 s 1
MEDICARE SUPPLEMENT INSURANCE
Delaware has amended Title 18, Chapter 34 of the Insurance Code to establish a special open enrollment period for individuals with Medicare supplement policies and to allow transitions from Medicare Advantage plans. Effective annually around a policyholder’s birthday, this new enrollment window permits switching to another Medicare supplement policy with equal or lesser benefits without denial or pricing discrimination based on health status. The bill also allows individuals to move from Medicare Advantage to supplement policies during the federal open enrollment period, subject to individual rating and preexisting condition limits. Insurers must notify eligible individuals 30–60 days before the special enrollment period begins. SB 71
PHARMACY BENEFIT MANAGERS
Colorado updated the annual registration process for pharmacy benefit managers (PBMs). Changes include clarifying that the regulation applies to all PBMs “doing business” in the state, adjusting registration deadlines, and outlining review procedures that allow for suspension or denial with written justification and response rights. PBMs must now renew annually based on their approval date and may have their applications processed by third-party vendors. 3 CCR 702-Reg. 4-2-97
Delaware tightened rules around overpayment recovery and pharmacy audits by insurers, health plans, and PBMs. The bill reduces the timeframe for initiating overpayment recovery from 24 to 12 months and requires concrete evidence of fraud or misconduct to bypass this limit. It also mandates written notice and justification for PBM recoupments and limits extrapolation in audits. HB 212
Massachusetts issued a bulletin outlining new licensure requirements for Pharmacy Benefit Managers (PBMs), effective January 1, 2026. All PBMs must obtain a license from the Division of Insurance by submitting a complete application by October 15, 2025, with a $8,334 filing fee. Bulletin 2025-04
Michigan reminds pharmacy benefit managers (PBMs) of their legal duty to fully cooperate with investigations under the PBM Licensure and Regulation Act and the Third Party Administrator Act. PBMs must provide requested documents and data to DIFS without delay or conditions, and all investigation materials are confidential. Noncompliance may lead to administrative actions, including fines, license suspension, or revocation. Bulletin 2025-20-INS
PREMIUM TAX
Colorado will repeal the reduced insurance premium tax rate for insurers with a home or regional home office in the state beginning January 1, 2026, due to its ineffectiveness in encouraging local workforce growth. The bill raises the tax rate from 1% to 2% and eliminates related statutory provisions by December 31, 2026. HB 1003
REGULATORY REPORTING REQUIREMENTS
Illinois now requires all health insurance issuers to submit and publicly post drug formularies via SERFF by October 1, 2025, including filings for both enrolled individuals and certain health products without enrollees. This requirement applies to new, returning, or expanding issuers and remains effective beyond 2026 unless amended. Bulletin 2025-16
UTILIZATION REVIEW - HEALTH CARE
Arizona issued a bulletin to guide health care insurers on complying with updated prior authorization laws under H.B. 2054. While the requirement for medical director signatures on denial letters has been removed, insurers must still provide written explanations, notify providers within required timeframes, and maintain records identifying the licensed medical professional responsible for each denial. Bulletin 2025-06
Newsletter
Life and Health News September 2025
Life and Health News
September 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!
ADVERTISING / SALES & MARKETING
New Mexico updated its rules on value-added products and services offered by insurers, allowing such offerings at no or reduced cost if they meet criteria like relevance to coverage, reasonableness, non-discrimination, and documented evidence. Insurers must notify the DOI via a SERFF filing with a $15 fee before offering these products. The bulletin clarifies that these exceptions apply only to insurers - not producers - and outlines procedures for rider issuance and dispute resolution. Bulletin 2025-006
AFFORDABLE CARE ACT
United States Department of Health and Human Services (HHS) issued the Marketplace Integrity and Affordability Final Rule on June 25, 2025, aimed at improving ACA Exchange affordability and integrity, with an effective date of August 25, 2025. However, key insurance-related provisions - including premium penalties for late eligibility updates, issuer coverage denials for unpaid premiums, special enrollment verification, and income verification processes - have been stayed by a federal court pending litigation. These stays delay enforcement of several regulatory changes impacting Exchange enrollees, issuers, and eligibility verification. CMS Notice Dated 8/25/25
United States health plans must use a good faith interpretation of the 2023 Qualified Payment Amount (QPA) calculation pending a final court decision, while continuing required QPA disclosures. FAQs were issued regarding implementation of the No Surprises Act and Affordable Care Act under the Consolidated Appropriations Act, 2021, Part 71. For the 2026 plan year, the premium adjustment percentage is 1.6727, with maximum out-of-pocket limits of $10,600 for self-only and $21,200 for other coverage. CMS Notice Dated 7/30/25
CREDIT INSURANCE
Arizona issued an order effective February 1, 2026, updating prima facie credit life insurance rates and capping monthly rates at $0.84 per $1,000 for single life and $1.39 for joint lives. Order Dated 7/31/25 - Docket No. 25A-005-INS
South Carolina issued a bulletin proposing a 15% reduction in credit accident and health insurance rates for 2026 to meet a minimum 50% loss ratio, reflecting historically low loss ratios from 2021-2024. The bulletin sets single premium rates per $100 of initial indebtedness for various coverage terms and requires non-single premium rates to be actuarially equivalent. Bulletin 2025-06
CYBERSECURITY
Colorado amended its regulations to set governance and risk management standards for insurers using external consumer data, algorithms, and predictive models in individual life, private passenger auto, and health insurance. The regulation aims to prevent unfair discrimination, requires detailed oversight frameworks, and mandates compliance reporting via SERFF, with operative deadlines starting December 1, 2024, for life insurers and July 1, 2026, for auto and health insurers. 3 CCR 702 Reg. 10-1-1 s 1 +
North Dakota updated its data security rules, requiring all licensed entities to implement a tailored Information Security Program and report cybersecurity events impacting 250 or more consumers within three business days. These changes include prompt investigations and five-year record retention. Bulletin 2025-1
DENTAL INSURANCE
Illinois now allows insured individuals under dental insurance policies, in addition to accident and health insurance policies, to assign their rights and privileges under the policy, including claims to dental care providers or facilities. Payment for assigned claims must be made directly to the dental care provider or facility, and interest requirements for delayed payments apply. SB 1392
Illinois updated the Uniform Electronic Transactions in Dental Care Billing Act to standardize electronic billing and reimbursement processes for dental plan carriers and providers, introduce a HIPAA-compliant eligibility and benefit verification portal, extend the deadline for mandatory electronic claims and eligibility transactions to 2027, and allow exemptions for certain dental providers. HB 1864
DEPENDENT COVERAGE
Illinois amended its Insurance Code to exclude student health insurance from the requirement that group or individual accident and health policies offering dependent coverage must also cover the insured’s parent or stepparent if specific conditions are met. HB 1577
DISASTER / CATASTROPHIC EVENT
North Carolina instructs health benefit plans to allow insured individuals affected by Hurricane Erin to obtain extra prescription medications during the declared state of emergency, applying to health plans and stand-alone prescription drug plans. Bulletin 25-B-10
DISCRIMINATION
Illinois amended rules for final expense life insurance to prohibit denying coverage, limiting benefits, or charging different rates solely based on a felony conviction, while allowing insurers to exclude those actively incarcerated. The amendment also provides a clear definition of "final expense policy." HB 2425
FILING REQUIREMENTS / PROCEDURES
Alabama issued a bulletin mandating the exclusive use of SERFF for all rate and form filings and requiring electronic funds transfer (EFT) for fee payments. The bulletin consolidates and replaces multiple earlier directives and establishes detailed filing fees across various insurance lines, with a maximum fee of $5,000 per SERFF submission. Bulletin 2025-04
HEALTH INSURANCE - COMPREHENSIVE
Illinois amended health insurance rules to protect insured individuals from higher out-of-pocket costs for neonatal intensive care received from nonparticipating providers or facilities. The amendment requires insurers to ensure these costs do not exceed what would be charged by participating providers when billed as emergency services. HB 2464
Illinois requires all group and individual health insurance policies and managed care plans issued or renewed after January 1, 2027, to cover medically necessary laser hair removal when prescribed according to accepted medical standards. This mandate applies broadly across state and local government health plans but excludes Medicaid recipients. HB 3248
Illinois revised its regulations to impose a $5,000 monthly fine on insurers that fail to update provider directories on time. Providers must report changes within 10 business days, and insurers must update directories within 2 business days. Self-audits of directories are required every 90 days, with reports submitted to the Department and made public. Printed directories must be updated quarterly and include contact details, accuracy disclosures, and instructions for reporting errors or disputing charges. HB 3800; 215 ILCS 124/25
New Mexico provided updated guidance for issuers of major medical plans, requiring the use of standardized prior authorization language in Evidence of Coverage documents and continued filing of the unchanged Administrative Data template for Qualified Health Plans in SERFF. The bulletin also introduces standardized discontinuation and auto-renewal notice forms to help issuers manage plan discontinuations and assist enrollees in transitioning to new plans. Bulletin 2025-007
New Mexico updated its Prior Authorization Act, removing prior authorization and step therapy requirements for FDA-approved off-label drugs used to treat rare diseases, autoimmune disorders, cancer, and substance use disorders, unless biosimilars or generics are available. Health insurers must ensure medical necessity reviews are done by specialists within set timeframes, with automatic approval if deadlines are missed, and submit compliance evidence to the OSI. The changes apply to fully insured health plans issued after July 1, 2025. Bulletin 2025-005
Oregon now prohibits billing enrollees beyond in-network cost-sharing for covered ground ambulance services and requires insurers to reimburse providers at local rates or at least 325% of Medicare rates. Providers must annually report rates to the Department of Consumer and Business Services. The law also allows certain self-funded plans and public employee benefit boards to opt in, with penalties for repeated violations. HB 3243
Texas extended payment standards and balance billing prohibitions for emergency medical services through September 1, 2027. Instead of mandatory payment adjustments, political subdivisions may annually report rate data, which sets the payment standards. The DOI reopened its data portal for 2025 rate submissions due by September 1, 2025, with prior 2024 data remaining effective if no new rates are submitted. Bulletin B-0011-25
LIMITED BENEFIT CONTRACTS
United States Departments of Labor, Health and Human Service, and Treasury (Tri Agencies) issued final rules titled "Short Term, Limited Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage." The Tri-Agencies have since announced they do not intend to prioritize enforcement actions for violations related to failing to meet the definition of "short-term, limited duration insurance" in the 2024 final rules, including the notice provision. States are encouraged to adopt a similar approach to enforcement. CMS Notice Dated 8/7/25
MEDICARE SUPPLEMENT INSURANCE
Rhode Island notified Medigap insurers about CMS’s designation of UnitedHealthcare’s termination of its contract with Brown University Health as a significant network change, triggering a Special Election Period (SEP) for affected Medicare Advantage enrollees. This SEP allows impacted members to disenroll and return to Original Medicare, with Medigap guaranteed issue rights enabling eligible individuals to purchase specific Medigap plans under federal rules. Advisory 2025-1
MENTAL HEALTH PARITY
Connecticut updated its annual reporting requirements for mental health and substance use disorder (MH/SUD) parity compliance, replacing Bulletin MC-24-A. Effective March 1, 2026, carriers must submit detailed reports analyzing the application of non-quantitative treatment limitations (NQTLs) to ensure parity with medical/surgical benefits. Incomplete or late filings may result in penalties. Bulletin MC-24B
MISCELLANEOUS
California issued a bulletin outlining year-end review procedures for corporate applications requiring Department of Insurance approval by the end of 2025. The notice sets deadlines - September 15 for general filings and October 13 for Holding Company Act applications - and requires perfected submissions with all documentation and justification for urgency. Notice Dated 8/15/25
Federal Exemptive Relief Order delays the effective date of the Investment Adviser Rule (Investment Adviser Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers). The rule was set to become effective on January 1, 2026, but a new effective date of January 1, 2028, is being proposed. FinCEN Order dated August 5, 2025
Illinois updated its small estate affidavit rules, raising the estate value limit for transferring personal property (excluding motor vehicles) to $150,000. The changes also clarify procedures for transferring motor vehicles and require detailed vehicle information on the affidavit. These provisions apply to estates of decedents who pass away on or after the effective date. SB 83
Illinois now requires coverage for emergency and urgent ground ambulance services from nonparticipating providers starting January 1, 2027. Insurers must ensure beneficiaries pay no more out-of-pocket than they would with participating providers, pay nonparticipating providers directly, and prevent balance billing beyond standard cost-sharing. Additionally, nonparticipating providers must annually report charge rates to the Department of Public Health. HB 2785
PHARMACY BENEFIT MANAGERS
Oregon updated rules for Pharmacy Benefit Managers (PBMs) and Drug Price Transparency reporting. Key changes include requiring PBMs to be licensed (not just registered), report detailed aggregated data on rebates, fees, and pricing annually, and comply with new operational standards that protect pharmacies from certain fees and restrictive practices. Insurers must also report prescription drug cost data annually without minimum enrollee thresholds. OAR 836-053-1630
Pennsylvania addressed pharmacy network adequacy following Rite Aid’s bankruptcy and closures. Insurers must notify the Department if closures impact network standards and provide alternative access plans, including out-of-network options with in-network cost-sharing. The notice requires proactive patient communication, smooth prescription transfers, expedited prior authorizations, and flexible pharmacy audits to ensure uninterrupted medication access. Notice 2025-07
REPLACEMENT - LIFE & ANNUITY
Arkansas updated requirements for replacing life insurance policies and annuity contracts, rescinding Bulletin 8-2009. Life insurers may now use their own replacement memorandums - rather than a prescribed format - as long as they clearly compare the existing and replacement products. Bulletin 10-2025
TRADE PRACTICES
Illinois updated its rules to prohibit soliciting accident or health insurance from individuals over 65 or in nursing homes unless safeguards like reviewing current coverage, involving family, and a 48-hour waiting period are followed. It also restricts policy changes for those with diminished capacity without authorized consent and empowers the Insurance Director to void policies that violate these provisions. HB 1865
UTILIZATION REVIEW - HEALTH CARE
Pennsylvania issued a notice establishing fee schedules for Independent Review Organizations (IROs) as required by Act 146 of 2022. The notice details fees for standard and expedited external reviews of adverse benefit determinations across Medicaid/CHIP, commercial insurance, and experimental/investigational cases, emphasizing fees must be reasonable and customary. Certification of IROs, valid for two years, depends on meeting statutory standards, including fee reasonableness. Notice 2025-08
Newsletter
Property & Casualty News January 2024
Property & Casualty News
January 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
California published a bulletin for all admitted Property and Casualty insurers. The bulletin reminds carriers of the requirements of Proposition 103, which requires carriers to file all changes to rates, rules, eligibility, and underwriting requirements and to offer and sell insurance to all persons who qualify as good drivers. Bulletin 2023-7
Michigan published notice that auto insurers, writing insurance in the state of Michigan, are required to pay an assessment to the Automobile Theft Prevention Authority, no later than 04/01/24. The assessment will be based on $1 per written car year of motor vehicles insured. The report is to be submitted with the online GRANTS-055 form. Letter Dated 01/04/24
New York passed a law requiring insurers who use a driving history as a rating or underwriting factor for private passenger motor vehicle insurance to first verify the driving history of the applicant and all named drivers using a third-party database. SB 5764
CLAIMS/CLAIMS ISSUES
Florida adopted rules defining requirements for claims handling manuals used by residential insurance companies. Insurers must file an annual attestation and certification of compliance with the Florida code. 690-171.012
CREDIT INFORMATION
District of Columbia approved a bill requiring credit reporting companies to accept a personal statement from a consumer indicating the consumer experienced financial hardship resulting from a public health emergency. Insurers, and other users of credit reports are prohibited from taking adverse action in these situations. B 118
FILINGS: PROPERTY/CASUALTY
District of Columbia enacted legislation amending certain personal lines product filing standards from file and use to prior approval, with a 90-day deemer. Insurers are also required to give an insured written notice, of at least 45 days before renewal. B 150
Nebraska's Department of Insurance published a notice regarding Model-Dependent P&C SERFF Rate Filings. Notice dated 12/28/23
Texas' Commissioner of Insurance adopted rules to exempt 12 additional specified commercial lines of insurance from rate and form filing requirements. 28 TAC s 5.5201
MARKET CONDUCT EXAMINATIONS
Florida adopted a rule governing its market conduct examination priority methodology. The rule identifies four levels of priority including statutory examinations, post-hurricane examinations, identified market concerns and non-statutory examinations. FAC 690-138.003
MISCELLANEOUS
Michigan published an updated annual schedule of fees including licensing, application, and examination fees. Bulletin 2023-24 BT
NOTICE TO INSUREDS
Illinois published a notice to Farm Mutual companies writing property and casualty insurance. Insurers are notified that any Farm Mutuals converting from unlimited catastrophic to "adequate" catastrophic reinsurance are required to provide notice to policy holders in a form as prescribed by the department. Bulletin 2023-17
PERSONAL LINES INSURANCE
Oregon promulgated a rule and created a model form used to attest the total loss of contents of a residence after a major disaster. OAR 836-080-0245
PROPERTY INSURANCE
Florida adopted a rule requiring insurers intending to temporarily suspend writing new residential property insurance to submit specified notification in IRFS. FAC 690-137.014
Louisiana published a notice that a number of fire districts had received improved ratings during 2023. Since this may allow certain policyholders to receive lower fire insurance premiums, policyholders are encouraged to contact their insurers. Notice of 12/19/23
REINSURANCE
New Jersey's Department of Insurance, Office of Solvency Regulation published an updated list of accredited reinsurers. Notice dated 12/11/23
West Virginia's Department of Insurance issued a list of active accredited reinsurers and trusteed reinsurers. Notice dated 12/31/23
REPORTS - DATA CALLS & OTHER REPORTS
Oklahoma's Insurance Department gave notice that it changed the reporting templates and added lines of business to the 2023 Pre-Disaster data call due March 1, 2024. Data this year must be reported by line of business rather than in aggregated format as in the past. Notice dated 12/18/23
Tennessee's Insurance Commissioner reminds all insurers of the requirement to file the annual fire loss reports on property insured in the state by February 1, 2024. Bulletin 23-07
SURPLUS LINES
Oklahoma's Insurance Department announced surplus lines brokers must use the Surplus Lines Automation Suite for the reporting and payment of premium taxes beginning January 1, 2024. Notice dated 12/13/23
WORKERS' COMPENSATION
Alaska published a bulletin reminding carriers of the annual reporting requirements for workers’ compensation. Specified reports must be submitted electronically no later than 03/01/24. WC 23-07
Connecticut published a memorandum announcing a change in the amount of contingency fees allowed in workers’ compensation proceedings. Fees will increase from 20% to 25%, subject to approval by an administrative law judge. Memorandum 2023-09
New Jersey's Department of Labor and Workforce Development announced that the state's minimum wage will increase to over $15 an hour. As a result, the workers’ compensation maximum weekly benefit amount increases to $1,131 from $1,099. Notice dated 12/27/23
Oregon issued a temporary emergency rule relating to new medical billing codes for 2024 for use by health care providers and workers' compensation insurance carriers. OAR 436-009-0004
Oregon's Workers' Compensation Division notifies insurers and self-insured employers of the 2024 claims processing administrative cost factor. This factor is applied to reimbursement for workers' compensation supplemental disability benefits and certain claim costs. Bulletin 316 (Revised)
Pennsylvania's Compensation Rating Bureau announced a newly revamped and modernized Experience Rating Worksheet representing the first comprehensive overhaul in over 25 years. PCRB Circular 1801
Virginia's Workers' Compensation Commission announced a mileage reimbursement rate increase. WC News dated 01/04/24
Newsletter
Life and Health News August 2025
Life and Health News
August 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!
CAPTIVES
Connecticut enacted legislation updating captive insurance laws to allow certain captive insurers to convert into protected cells with the insurance commissioner’s approval. The law permits sponsored captive insurance companies to transfer protected cells to other licensed entities and authorizes the commissioner to separate and restructure insolvent protected cells. HB 6433
CLAIMS / CLAIMS ISSUES
Nebraska announced that life insurers must pay interest on death claims not settled within 30 days of proof of loss, with the interest rate set at 6.213% effective April 17, 2025, and adjusted to 6.256% on July 17, 2025. Notice of 7/7/25
CREDIT INSURANCE
Arkansas updated its credit life and credit disability insurance regulations under Rule 12, removing notarized affidavit requirements for agent compensation. The revised regulations set comprehensive standards for forms, rates, benefits, disclosures, claims handling, and agent compensation for credit insurance tied to loans or credit transactions under 10 years. They apply to insurers, agents, brokers, and creditors, and include provisions on refund formulas, rate filings, financial reserves, penalties, and insurer reporting requirements. 23 CAR s 83-101
Illinois amended rules on credit life insurance policy exclusions and premium rates, noting that non-compliant policy forms and rates will be losing approval after August 20, 2025. Insurers are required to submit updated filings to comply. Bulletin 2025-14
New Mexico announced updated presumptively acceptable premium rates for credit life and credit accident and health insurance. Insurers adopting these rates must submit a SERFF filing with an actuary’s attestation, while others must file full rate materials for review. Bulletin 2025-002 (Updated)
CYBERSECURITY
New York issued guidance urging regulated entities to strengthen cybersecurity and sanctions compliance amid global conflicts, emphasizing adherence to 23 NYCRR Parts 500 and 200. The guidance mandates enhanced risk assessments, incident reporting, transaction monitoring, and tailored controls for virtual currency businesses to prevent sanctions evasion. Industry Letter of 6/23/25
Oklahoma released a revised bulletin that updates requirements under the Insurance Data Security Act, establishing comprehensive data security, cybersecurity event investigation, and reporting protocols for licensed entities under Title 36, with specified exemptions and deadlines for compliance. Bulletin 2024-10 (Revised)
DENTAL INSURANCE
Colorado’s Dental Board amended its regulations to require dentists, dental therapists, and dental hygienists, to disclose potential balance billing to patients receiving certain out-of-network services at in-network facilities. The updates to 3 CCR 709-1 § 1.30 and Appendix B clarify when balance billing is permitted and outline provider disclosure obligations in multiple languages. 3 CCR 709-1 s 1.30
HEALTH INSURANCE - COMPREHENSIVE
Alaska enacted legislation establishing standardized, transparent, and technology-enabled prior authorization processes for health care insurers. The bill mandates specific timelines, peer review standards, API use, and limits on step therapy protocols, particularly for advanced cancer and other qualifying conditions. It also requires annual insurer reporting and imposes penalties for violations. SB 133 - Chapter No. 2025-21
HOLDING COMPANIES
South Carolina published a bulletin that details amendments to the Insurance Holding Company Regulatory Act and Investments of Insurers Act, enhancing regulatory oversight through group capital calculations, liquidity stress tests, and revised investment limits for insurers. These changes apply to all financial statements due on or after August 15, 2025, and aim to strengthen risk assessment, transaction oversight, and investment restrictions. Bulletin 2025-04
MEDICARE SUPPLEMENT INSURANCE
Texas released a bulletin announcing that, effective September 1, 2025, House Bill 2516 requires Medicare Supplement plans to offer equal coverage and rating protections to Texans under 65 with ESRD or ALS as those 65 and older, prohibiting medical underwriting, waiting periods, and preexisting condition exclusions. A special enrollment period from December 1, 2025, to June 1, 2026, allows eligible individuals to enroll under these protections. Bulletin B-0010-25
Wyoming released a bulletin clarifying updates to Insurance Regulation Ch. 35, including the new "birthday rule" that provides Medicare Supplement policyholders a 63-day guaranteed issue period starting on their birthday annually. Policyholders with birthdays on or before June 4, 2025, retain eligibility through the full 63-day window following their birthday. Bulletin 06-2025
MENTAL HEALTH PARITY
California updated its insurance regulations to strengthen enforcement of the Mental Health Parity Act, ensuring health insurers provide equal coverage for mental health and substance use disorder services. The regulations implement SB 855 and AB 988 by aligning utilization review with current clinical standards, integrating behavioral health crisis services, and requiring coverage for out-of-network care when necessary. Reg. T. 10 s 2562
Illinois announced that it will continue enforcing the 2024 Final Rule under the federal Mental Health Parity and Addiction Equity Act (MHPAEA) despite the HHS federal decision not to enforce certain amendments, affirming that the rule remains in effect and enforceable in Illinois unless legally repealed or superseded. Bulletin 2025-10
MISCELLANEOUS
Ohio’s new law, effective September 30, 2025, exempts certain nonprofit agricultural membership organizations from insurance regulations, clarifying that their healthcare benefit coverage is not considered insurance and is not subject to state insurance laws, provided the coverage is only offered to members and their families and clearly disclosed as non-insurance. SB 100
MISCELLANEOUS LIFE / ANNUITY
Idaho announced that insurers must pay a minimum interest rate of 9.125% on deferred cash surrender payments for life insurance and individual deferred annuities if payment is not made within 30 days of the policyholder’s request, with the rate reviewed annually by the State Treasurer. Bulletin 25-05
OMNIBUS LEGISLATION
Alaska enacted a comprehensive insurance reform bill that streamlines premium tax calculations, enhances consumer protections, and expands regulatory oversight. The law mandates licensure for TPAs and PBMs, increases examination authority of the Division of Insurance, and amends numerous provisions related to health care policies, trade practices, surplus lines, and insurer operations. It also introduces new requirements for insurer responses, policy renewals, and contract filings. SB 132 - Chapter No. 2025-17
PHARMACY BENEFIT MANAGERS
Connecticut announced that beginning March 1, 2026, and annually thereafter, Pharmacy Benefit Managers managing pharmacy benefits for health carriers must report the total rebates collected and retained from pharmaceutical manufacturers for outpatient prescription drugs. Reports must be submitted via an online survey provided by the Insurance Commissioner. Notice to PBMs Dated 7/17/25
Illinois now requires Pharmacy Benefit Managers to report covered individuals by August 1, 2025, and pay a fee of $15 per covered individual by September 1, 2025, under Public Act 104-0027. Bulletin 2025-13
Louisiana announced amendments to Regulation 90, updating pharmacy and pharmacist claims payment rules to include new audit and claim review requirements and mandating submission of compliance policies and procedures to the DOI. LAC 37:XIII.11501
North Carolina’s enacted legislation which regulates pharmacy benefits managers (PBMs), pharmacy services administrative organizations (PSAOs), and drug manufacturers to improve transparency, protect consumers, and support community pharmacies by enforcing licensing, reporting, audit limitations, pricing disclosures, and prohibiting unfair practices in pharmacy benefit management and prescription drug
PRE-NEED CONTRACTS
North Carolina’s revised its funeral service laws to exempt transportation protection agreements from preneed and life insurance regulations, enhance licensure requirements including criminal background checks, and strengthen the Board of Funeral Service’s authority to enforce compliance. HB 1003
REGULATORY REPORTING REQUIREMENTS
Indiana now requires insurers, TPAs, and PBMs to annually report ownership information starting July 1, 2025, under Public Law 239-2025, with penalties for late or non-compliance including fines and disciplinary actions. Bulletin 279 dated June 26, 2025
New Hampshire announced that effective September 13, 2025, insurance companies must notify the Department of Insurance and appointed agents before discontinuing entire lines of business, including Medicare Advantage Plans, with notice periods ranging from 90 to 120 days depending on the type of insurance and action. SB 121
REINSURANCE
West Virginia released an update, publishing their quarterly list of accredited and trusted reinsurers, detailing company names, domicile types and states, company and organization types, FEIN, NAIC codes, group numbers, state legacy IDs, and status. Notice Dated 6/30/25
REPORTS - DATA CALLS & OTHER REPORTS
California’s Department of Insurance announced that the 2024 SIU Annual Report must be submitted electronically by 11:59 PM (PT) on September 15, 2025. The DOI will host virtual workshops on August 20, 2025, to review submission requirements and answer questions. SIU E-Blast 2025-20
Illinois announced a Climate Risk Disclosure Survey for 2024, requiring insurers with over $100 million in direct premiums to submit climate-related financial data by August 29, 2025. Bulletin 2025-11
New Jersey announced that licensed insurers with over $100 million in direct written premiums must submit the NAIC Climate Disclosure Risk Survey aligned with TCFD by August 29, 2025, or submit to another participating jurisdiction if applicable. Bulletin 25-05
New Mexico announced updates to the Surprise Billing Data Call Template under the Surprise Billing Protection Act, requiring health carriers to submit expanded claims data for plan years 2021, 2022, and 2024. Accurate and complete submissions are mandatory to avoid penalties. For Plan Year 2024, the filing is due by 9/1/25. For Plan Years 2021 and 2022, the filing is due by 10/1/25. Bulletin 2025-003
South Carolina released a bulletin that requires insurers licensed for life, accident, and health insurance to submit data on paid family leave insurance coverage for the past three years by August 31, 2025, in compliance with Title 38, Section 103. The data call applies to all insurers offering paid family leave benefits and mandates completion of a spreadsheet template. Notice Dated 7/1/25
TRADE PRACTICES
New York issued FAQs clarifying Insurance Circular Letter No. 6 (2023), which addresses unfair and unlawful discrimination in life insurance and annuity sales. The guidance helps ensure compliance by reviewing product portfolios. Life Bureau Filing Guidance of 7/23/25
TRAVEL INSURANCE
Hawaii enacted the Hawaii Travel Insurance Act to establish a legal framework regulating the sale of travel insurance in the state. The Act governs licensing, registration, sales practices, and taxation of travel insurance policies covering Hawaii residents, and takes precedence over general insurance laws for travel insurance-specific matters. It sets requirements for producers, travel retailers, and administrators. HB 97
Hawaii's Insurance Commissioner issued guidance on the newly enacted Hawaii Travel Insurance Act, clarifying regulatory distinctions between travel-related accident and health or sickness-only products and those with property and casualty benefits. The Insurance Division will continue reviewing group health-related travel policies under existing disability insurance requirements, and producers selling such policies must hold a valid accident and health or sickness license under Article 10A. Memorandum 2025-4R
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