Resources
Newsroom
Newsletter
Life and Health News May 2025
Life and Health News
May 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
Kansas enacted the Protected Cell Captive Insurance Company Act, establishing a framework for the creation and operation of protected cell captive insurance companies. The act requires separate accounting for each cell’s assets and liabilities, allows for both incorporated and unincorporated cells, and mandates commissioner approval for the formation process. HB 2334
CONFIDENTIALITY / PRIVACY
Rhode Island issued a bulletin to guide insurers on complying with the state’s new insurance data security law which adopts provisions of NAIC Model #668. The bulletin clarifies expectations for domestic and foreign insurers, including annual compliance statements, cybersecurity incident reporting, and proportional implementation of information security programs based on insurer size and complexity. It also emphasizes insurers' responsibilities regarding third-party service providers and outlines public disclosure requirements following a data breach. Bulletin 2025-1
CORPORATE GOVERNANCE
Nebraska updated qualifications for insurance corporation boards under section 44-211, requiring at least five directors and mandating one be a Nebraska resident unless a five-year waiver is granted. LB 325
DENTAL INSURANCE
Kentucky enacted a new law requiring insurers of dental benefit plans to honor written assignments of benefits from insured individuals to dental service providers. The law mandates that assignments be made using a standardized form, signed by both the insured and the provider, and ensures payments are made directly to providers according to the same criteria as original providers. HB 210
New Mexico now requires health insurance carriers to load approved dentists and dental hygienists into their payment systems within 30 days of receiving a complete credentialing application. Carriers must reimburse dental providers for covered services during credentialing delays, with reimbursement terms based on employment status, and with protections in place for licensed, insured providers. HB 402
North Dakota amended its insurance code to prohibit preferred provider arrangements from restricting covered individuals from receiving, or paying for, additional dental care services denied by their dental plan. The law also ensures that, unless disclosed beforehand, covered individuals cannot be charged more than the contracted rate for those services under the preferred provider agreement. SB 2377
FILING REQUIREMENTS / PROCEDURES
Texas updated its insurance regulations regarding the filing process for life, health, and annuity products, including HMO filings. The changes modernize requirements for filings, enhance consumer protections, and introduce clearer rules on premium payments and third-party involvement. 28 TAC s 3.1+
FRAUD / ANTI-FRAUD
Illinois issued a bulletin clarifying that insurers are not required to establish regular fraud reporting programs, either to the Department or third-party organizations, and participation is voluntary. The bulletin encourages reporting workers’ compensation fraud and consumer fraud through designated units but emphasizes that Illinois lacks a general insurance fraud bureau. For criminal cases, insurers are advised to report to the relevant law enforcement agency. Bulletin 2025-06
HEALTH CARE EXCHANGE / MARKETPLACE
Massachusetts issued guidance for insurers regarding policy form material submissions for merged market health and dental plans. The guidance requires inclusion of essential health benefits, adherence to federal actuarial value standards, and alignment with updated network adequacy requirements. Carriers must submit provider data to Quest Analytics by May 15, 2025. Filing Guidance Notice 2025-M
HOLDING COMPANIES
Illinois amended its insurance regulations to clarify prior notification requirements for transactions within insurance holding company systems. The rule updates standards for director disapproval within 30 days of complete notice, revises references to the AIC Accounting Practices and Procedures Manual, and strengthens requirements for cost-sharing and management services agreements to align with the NAIC model regulation. 50 Ill. Adm. Code 654.30
New Mexico updated its insurance code to authorize group capital calculation reports and liquidity stress tests for insurance holding companies. The Health Maintenance Organization (HMO) law is also amended to extend the examination timeline from every three years to at least five years. HB 398
LIFE SETTLEMENTS / STOLI
Idaho updated its rules on life settlements to revise definitions, remove specific registration and disclosure requirements, eliminate mandatory form filings, and repeal annual reporting obligations. The rule also updates provisions related to settlements occurring within two years of policy origination. IDAPA 18.03.02
North Dakota updated its licensing rules for life settlement producers by standardizing renewal terms for all licenses issued after January 1, which now must be renewed by April 30 of the following year. The amendment aligns provider license terms with domestic stock life insurance companies and broker license terms with insurance producer licenses. Licenses will expire if not renewed by the deadline. SB 2092
LONG-TERM CARE INSURANCE
North Dakota enacted new standards for long-term care insurance policies, requiring clear definitions for certain terms when used in policies. The law prohibits insurers from delaying or denying benefits to basic care facilities if the insured is eligible. It also mandates that insurers provide a copy of the policy to the insured or their representative within 30 days upon request. SB 2172
MEDICARE SUPPLEMENT INSURANCE
Indiana enacted new legislation to establish eligibility criteria for Medicare supplement policies. The law ensures that individuals applying within a six-month window after turning 65 and enrolling in Medicare Part B are not penalized, and allows current policyholders to switch issuers within 60 days of their birthday while maintaining their plan type. It also prohibits discrimination in policy pricing based on health status or medical condition for eligible applicants. HB 1226
Louisiana introduced a "Refund Filing Template" to streamline compliance with Regulation 33 for Medicare Supplement policies. Louisiana issued this directive mandating all health insurance issuers, including health maintenance organizations, use the template for annual refund filings starting April 30, 2025. Directive 227
Utah amended its accident and health insurance laws to allow enrollees to choose a comparable or lower-tier plan annually without facing medical underwriting. Insurers are also now prohibited from denying coverage based on medical history. HB 258
MISCELLANEOUS
Colorado repealed its unconstitutional statutory ban on same-sex marriage, aligning state law with the U.S. Supreme Court’s 2015 Obergefell v. Hodges decision. Specifically, Colorado removed language defining marriage as between only one man and one woman. SB 14
Illinois updated its securities regulations to align with federal standards. The rule refines definitions, updates registration and education requirements for Investment Adviser Representatives (IARs), and introduces new continuing education mandates, with penalties for non-compliance. 14 Ill. Adm. Code 130.200
Kansas renamed the Kansas Insurance Department to the Kansas Department of Insurance. HB 2050
MISCELLANEOUS HEALTH / ACCIDENT
Arkansas enacted the Medical Audit Bill of Rights Act to standardize and protect healthcare providers during audits by health insurers. The law creates new processes and requirements for insurance companies, third-party payors, and entities who administer claim services. HB 1314
Arkansas expanded the Prior Authorization Transparency Act to implement a "Gold card program," allowing healthcare providers with high approval rates to bypass prior authorization requirements. The amendments define eligibility, duration, rescission procedures, and protections against payment denials for exempted providers. HB 1301
Arkansas now prohibits healthcare insurers from requiring step therapy or fail-first protocols for noninvasive ventilators when certain medical conditions are met. The new law ensures Medicaid managed care organizations reimburse for these ventilators at no less than 100% of the Arkansas Medicaid fee schedule. HB 1321
MISCELLANEOUS LIFE / ANNUITY
Tennessee amended its life insurance law to clarify that proceeds from life insurance policies or annuity contracts designated for a spouse, children, or dependent relatives are fully exempt from creditor claims. This protection shields the funds from execution, garnishment, or seizure—even after the proceeds are used. HB 1045
NOTICE TO INSUREDS
Illinois adopted amendments to the consumer complaint notification procedure, reflecting the shift to online consumer complaints. Insurers must now send notifications to policyholders upon policy renewal, and provide Department of Insurance (DOI) office locations for filing complaints. The amendments also update notification forms, clarify DOI contact details, and remove certain insurance exemptions. 50 Ill. Adm.
PHARMACY BENEFIT MANAGERS
Alabama amended the Pharmacy Benefits Manager Licensure and Regulation Act, establishing civil penalties and legal remedies for harmed parties, setting minimum reimbursements for independent pharmacies, and mandating full rebate pass-through to health plan clients. SB 252
Arkansas enacted the Pharmacy Nondiscrimination Act which ensures any willing pharmacy or pharmacist can join Pharmacy Benefit Manager (PBM) networks under fair terms, and prohibits discriminatory exclusions. Violations may result in fines up to $100,000, license suspension, or bans on selling PBM services. SB 103
REGULATORY REPORTING REQUIREMENTS
Mississippi issued a bulletin requiring all health insurance issuers, excluding ERISA and Workers’ Compensation plans, to submit an annual Prior Authorization Report starting June 1, 2025. The report must include aggregated, de-identified data on prior authorization requests, denials, appeals, and appeal outcomes. Bulletin 2025-2
North Dakota amended its insurance law to update how insurance companies publish abstracts of their annual statements, no longer requiring the commissioner to designate a single newspaper. Instead, companies must now use a standardized form and distribute the abstract across all newspapers within the judicial district where they operate. HB 1398
TRADE PRACTICES
Nebraska amended the Unfair Trade Practices Act to include health insurance lead generators. A health insurance lead generator is defined as a person who utilizes a lead generating device to: (a) publicize the availability of or what purports to be a health insurance product or service that the person is not licensed to sell directly to the customer; (b) identify a customer who may want to learn about health insurance, or (c) sell or transmit customer information to an insurer or producer for follow-up contact and sales activity. LB 326
UNCLAIMED PROPERTY
Montana amended the Uniform Unclaimed Property Act to modernize definitions and clarify abandonment rules. The changes add "payroll card" as a defined property type, update when such property is presumed abandoned, and allow notice to apparent owners via email if they've consented. HB 164
North Dakota updated its Revised Uniform Unclaimed Property Act to include virtual currency as property presumed abandoned after three years. The bill revises notice procedures for examinations, clarifies limitations periods, and allows claims on held property to offset state civil judgments. HB 1149
UTILIZATION REVIEW - HEALTH CARE
Arkansas updated the Prior Authorization Transparency Act to expand definitions, strengthen disclosure requirements, exempt certain services from prior authorization, and mandate timely insurer responses. The update also enforces claim payment obligations, defines prior authorization durations, and introduces penalties for non-compliance. HB 1300
Newsletter
Property & Casualty News October 2023
Property & Casualty News
October 2023
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!
AGENT / PRODUCER LICENSING AND APPOINTMENT
The Texas Insurance Commissioner updated the list of criminal offenses considered when a person with a criminal background applies for or renews an insurance license. 28 TAC s 1.502
AUTOMOBILE INSURANCE
New York now requires a carrier to provide (rather than offer) supplemental spousal liability (SSL) insurance in personal and commercial automobile policies. However, the named insured can decline or refuse the SSL coverage. The amended law contains other requirements. 11 NYCRR 60-1.6
CLAIMS / CLAIMS ISSUES
Oklahoma's Insurance Department notified Property & Casualty carriers they must include the Insurance Adjuster's Report, Claim Settlement Report, or claims statement or estimate when issuing claim settlement checks. Failure to do this may be considered an unfair claims settlement practice. Notice dated September 14, 2023
CONFIDENTIALITY / PRIVACY
California enacted certain privacy protections for individuals receiving medical treatment related to gender affirming care, abortion, contraception, and related medical treatment. Requirements to protect information are aimed at certain providers that store or maintain that type of information. AB 352
CREDIT FOR REINSURANCE
New Jersey's Department of Insurance, Office of Solvency Regulation published an updated list of eligible surplus lines reinsurers. All insurers domiciled, licensed or eligible to write surplus lines insurance in New Jersey or another state that has substantially similar standards are allowed to take full credit for reinsurance ceded to the listed reinsurers until September 1, 2024. Notice dated September 1, 2023
DISASTER / CATASTROPHIC EVENT
Hawaii's Insurance Commissioner issued a Memorandum encouraging all insurers providing residential property insurance to give insureds in areas impacted by the Maui wildfires at least 36 months of Additional Living Expenses, subject to policy limits. Memorandum 2023-5A
FILINGS: PROPERTY / CASUALTY
Arkansas’ Insurance Department announced an assessment to the members of the Arkansas Rural Risk Underwriting Association of $200. The assessment is due by 12-31-2023. Bulletin 15-2023
Delaware amended its regulations pertaining to rate and form filings, including adding a requirement that filings be submitted to the department no less than 60 days prior to the proposed effective date. The commissioner may extend the review up to 90 days by giving notice within 45 days of receipt of the filing, and the filing will not become effective until the later of department approval or the expiration of the extended time period. HB 228
FRAUD / ANTI-FRAUD
California enacted an amendment relating to false and fraudulent insurance claims. The amendment requires the insurer to provide the fraud warning on a form used when the person applies for a policy, seeks to amend insurance coverage, or furnishes information relating to underwriting criteria affecting premium or eligibility for coverage, under an existing policy, instead of when that person applies for a policy or seeks to make a change to an existing policy. SB 743
MISCELLANEOUS
California's Governor issued an executive order directing the insurance commissioner to take regulatory action to strengthen and stabilize California's homeowners and commercial property insurance marketplace. The regulatory response shall include improving the efficiency, speed, and transparency of the rate approval process. Executive Order N-13-23
Michigan published an updated list of all municipalities that participate in the Fire Insurance Withholding Program. Notice Dated October 1, 2023
Oregon's Insurance Commissioner issued a bulletin to identify the most common notice and filing issues/deficiencies and to remind producers and applicants of their responsibility to furnish the division with complete, accurate, and truthful information in all filings. Bulletin 2023-3
PROPERTY INSURANCE
Maryland issued a bulletin notifying insurers and producers of changes to the requirements for homeowners insurance for owners of detached condominium units. Beginning October 1, the homeowners' council is no longer required to maintain property coverage for detached units, but may voluntarily continue to provide coverage. The bulletin advises producers to confirm whether coverage is provided before making a recommendation to purchase coverage. Bulletin 23-15
REPORTS - DATA CALLS & OTHER REPORTS
California enacted legislation requiring the insurance commissioner to conduct data surveys to measure the availability and affordability of insurance for specified trucks. The bulletin will be published on or before 2-1-2024 and responses will be required by 5-1-2024. Results will be published. AB 844
SURPLUS LINES
Oklahoma's Insurance Department advises surplus lines agents and direct procurement filers that Oklahoma adopted the Surplus Lines Information Portal (SLIP) for reporting and payment of surplus lines premium tax. This is effective January 1, 2024. Bulletin 12-2023
TRADE PRACTICES
Delaware enacted legislation that prohibits an insurer from using any of the following when underwriting homeowner or private passenger insurance: non-pending arrests, charges and indictments that do not result in conviction, convictions unrelated to fraud or the risk being insured, or driver's license suspensions or revocations for non-driving related reasons. Use of any of these factors will be treated as unfair competition and unfair or deceptive act. SB 184
WORKERS' COMPENSATION
Arizona's Department of Insurance and Financial Institutions announced a 10.3% reduction in Workers Compensation Rates effective 1-1-2024. Press Release Dated 10-5-2023
Connecticut published a Workers' Compensation Memorandum updating the average weekly wage, maximum compensation rate and cost-of-living adjustments. MEMORANDUM NO. 2023-05
Kentucky adopted a rule to establish the proper calculation of the Workers' Compensation special fund assessment, set procedures to be used to collect the assessment, to allow for audits and define penalties. 803 KAR 30:010
Massachusetts published a circular letter updating the cost of living adjustments, minimum and maximum weekly compensation rates, and reimbursement schedules for workers' compensation benefits. Circular Letter 359
Nevada's Department of Business and Industry Industrial Relations published instructions for completing a D-35 Form to request an impairment evaluation rating of a possible permanent partial disability (PPD). Notice dated September 1, 2023
North Carolina's Department of Insurance approved the Rate Bureau's loss cost reference filing to become effective on April 1, 2024. Circular Letter C-23-11
The Texas Department of Insurance published the maximum and minimum weekly benefits under the Workers' Compensation Act for the period October 1, 2023, through September 30, 2024. WC Notice of Weekly Benefits 2024
Vermont General Assembly made numerous changes to workers' compensation law that directly affects the day-to-day adjustment of claims. This includes: 1) a change in the method for calculating temporary partial disability benefits; 2) an increase in the weekly benefit for each dependent child under age 21; and 3) an expansion of the preauthorization process for medical treatment. HB 217
Virginia's Department of Insurance approved the revision to NCCI Basic Manual Rules related to workers' compensation service charge and automatic gratuities for new and renewal policies on or after January 1, 2024. Administrative Order 12178
Washington announced its workers' compensation reimbursement rates for lodging, meals, and privately-owned vehicle mileage effective October 1, 2023. WC 2023 Mileage Reimbursement Rates Sept 2023
Wisconsin's Commissioner of Insurance approved Workers Compensation State Special Rating Values pages effective October 1, 2023. Circular Letter 3255
Wisconsin's Compensation Rating Bureau published details concerning the 2024 Financial Calls and Fining Program. An assessment for delinquent responses is levied. General Circular Letter 667
Newsletter
Property and Casualty News January 2025
Property and Casualty News
January 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!
AGENT / PRODUCER LICENSING AND APPOINTMENT
Oklahoma announced it will offer Insurance Producer and Adjuster licensing exams and Kaplan Financial study manuals in Spanish. The materials will be available in electronic and printed formats, with bundles for Life and Health or Property and Casualty exams available for purchase on the OID's website. Candidates can contact PSI Exams or the OID Licensing and Education Division for questions regarding scheduling or materials. Special Notice dated 12/23/24
Wyoming's Insurance Department requires insurance companies to renew their agent appointments for 2025 by paying the Annual Appointment Renewal Invoice by March 31, 2025. The Department will send invoices and appointment lists on February 1, 2025, and the last day to terminate appointments without incurring the renewal fee is January 31, 2025. Memorandum 12-2024
ARTIFICIAL INTELLIGENCE
Massachusetts' Division of Insurance issued guidance on insurers' use of Artificial Intelligence (AI) systems. It outlines expectations for insurers to develop written programs for the responsible use of AI, including risk management, governance, and internal controls to prevent unfair or discriminatory outcomes. The DOI may request specific information from insurers during examinations to ensure compliance. Bulletin 2024-10
North Carolina issued a reminder informing insurers that decisions supported by advanced technologies like Artificial Intelligence (AI) must comply with all insurance laws, including those addressing unfair practices and discrimination. The bulletin outlines regulatory expectations, emphasizes the importance of due diligence when using third-party AI systems, and specifies the types of information the Insurance Department may request for regulatory oversight. Bulletin 24-B-19
AUTOMOBILE INSURANCE
Colorado's Department of Insurance clarifies insurers' responsibilities regarding the payment of registration fees following the total loss motor vehicles. The bulletin applies to all insurers that provide motor vehicle policies in Colorado and addresses both first-party and third-party claims of total loss vehicles. Insurers must cover title fees, sales tax, and registration fees ranging from $2 to $20. Recent court rulings mandate payment of these fees in almost all total loss cases, with limited exceptions. Bulletin B-5.51
Maryland's Insurance Department clarifies that private passenger motor vehicle liability insurance carriers must provide a 45-day written notice to policyholders when increasing premiums based on telematics program data such as smartphone apps or GPS trackers. Insurers must justify the rate increase and ensure confidential data collected remains private. Bulletin 24-26
Massachusetts increased the minimum motor vehicle liability coverage amounts to enhance financial protection. The required coverage for bodily injury to one person rises from $20,000 to $25,000, for bodily injury per accident from $40,000 to $50,000, and for property damage from $5,000 to $30,000. These changes apply to policies issued or renewed on or after July 1, 2025. HB 5111
Pennsylvania's Insurance Department announced that it increased the accident surcharge dollar threshold for private passenger automobile insurance to $2,250. This adjustment prevents insurers from penalizing policyholders with rate surcharges or increased premiums as long as the aggregate claim cost does not exceed the new cap. Insurers must file the change discussed in the Notice for prior approval by April 1, 2025, for an effective date no later than July 1, 2025. Notice 2025-01
COMPANY LICENSING
Nevada's Division of Insurance announced the 2025 Annual Company Renewal process, requiring insurers to retrieve their Annual Renewal Invoice online through the Online Service Portal beginning January 3, 2025. Payment is due by March 1, 2025. Notice dated 12/16/24
CYBERSECURITY
Alaska informed licensees, admitted insurers, and other interested parties about SB 134, regarding insurance data security. The passed bill sets data security standards, including risk assessments, written information security programs, and response plans for cybersecurity incidents. Insurers are required to submit annual compliance certifications starting in 2026. Bulletin B 24-11
New York revised its General Business Law requiring businesses to notify affected individuals of a data breach within 30 days. The law also adds the Department of Financial Services to the list of entities that must be notified when a breach affects any New York resident. SB 2659
FLOOD INSURANCE
New York enacted a law limiting the amount of flood insurance mortgagees can require from mortgagors for residential properties. The coverage cannot exceed the outstanding principal mortgage balance and must exclude the property’s contents. Mortgagees must also notify mortgagors that the insurance protects only the lender's interest and may not cover repairs or losses from flooding. AB 5073
HOLDING COMPANIES
Maryland adopted amendments to clarify reporting requirements for insurance holding company systems effective January 6, 2025. The regulations specify when an annual group capital calculation is required, exemption criteria, and conditions for submitting a limited group capital filing. These changes aim to ensure adequate supervision of insurance systems and protect policyholder obligations. COMAR 31.04.18.02
FILING REQUIREMENTS/PROCEDURES
New Jersey's Department of Banking and Insurance issued an order regulating underwriting guidelines for private passenger automobile and homeowners insurance to prevent unfair practices. Insurers are required to submit their underwriting guidelines and file any changes to their rates or rating systems for insurance issued between certain specified dates. Order A24-09
PREMIUM TAX
Louisiana mandates that all companies required to file premium tax returns must do so online through the Industry Access Portal, including submissions of the Annual Premium Tax Statement (Form 1061) and Annual Municipal Premium & Tax Report (Form 1076). Companies seeking investment or military tax credits must also submit additional forms along with their tax returns. Notice dated 12/12/24
PROPERTY INSURANCE
Michigan updated the list of municipalities participating in the Fire Insurance Withholding Program, effective February 1, 2025. The program allows for the escrow of a portion of fire insurance settlements to address damages from fire, explosion, and other specified perils, with participation based on municipal population size. New municipalities will be notified at least 30 days prior to participation, and municipalities can update their information by submitting changes in writing. Notice dated 12/30/24
New York updated its Insurance Law to regulate parametric insurance, a new form of coverage for weather-related events based on the severity and proximity of such events as measured by government agencies. The law introduces parametric insurance as a recognized category, amends provisions for excess line brokers to procure policies from non-authorized insurers and adds disclosure requirements to ensure transparency. These changes include clarifications that parametric insurance is not a substitute for comprehensive coverage and integrate it into the broader regulatory framework for commercial and personal property/casualty insurance policies. AB 10344
REPORTS - ANNUAL / QUARTERLY STATEMENT
Connecticut's Insurance Department informed accredited reinsurers that annual financial statements and related filings must be submitted electronically to the NAIC or via email, for the 2024 reporting year. Reinsurers must file their financial reports by March 1, 2025, including actuarial opinions and management discussions. Bulletin FS-4AR-24
Connecticut issued a bulletin detailing the 2025 electronic financial statement filing requirements for all insurance companies, domestic surplus lines insurers and fraternal benefit societies authorized to operate in the state. These entities must submit their annual and quarterly financial reports electronically to the National Association of Insurance Commissioners (NAIC), with quarterly statements due on May 15, August 15, and November 15, 2025. Additionally, domestic insurers must report the physical locations of their invested assets and comply with specific requirements for reinsurance credit. Bulletin FS-4-24
Connecticut issued a bulletin outlining the 2025 financial filing requirements for captive insurers. Captive insurers must submit verified annual financial statements, including loss reserve opinions from qualified actuaries, and certified reports from independent accountants. These filings are due within 75 days after the end of the fiscal year and must be submitted electronically to the DOI. Bulletin FS-4C-24
Connecticut's Insurance Department issued a reminder to foreign eligible surplus lines insurers about their 2025 electronic financial statement filing requirements. Insurers must submit their annual financial report by March 1, covering the preceding December 31, and adhere to quarterly filing obligations. Additionally, policies must include a notice that the guaranty association does not protect these policies. Bulletin FS-4SL-24
North Dakota's Insurance Department has changed its process for publishing the abstract of the annual statement for each insurance company. Insurance companies must now submit their annual statement abstracts directly to the North Dakota Newspaper Association (NDNA) for publication, using a Self-Service Portal. Proof of publication must be submitted to the Commissioner within four months of filing the annual statement. Bulletin 2024-1
REPORTS - DATA CALLS & OTHER REPORTS
Florida amended Rule 69O-137.009 and Form OIR-D0-1185 to require insurers to report data for personal and commercial residential property by ZIP code instead of county, on a monthly basis rather than quarterly. The first report for January 2025 data is due by February 28, 2025. Rule 69O-137.009
SURPLUS LINES
Alabama now requires surplus line brokers to file quarterly reports on surplus-lines transactions in the state. The reports must be submitted by May 30, August 30, November 30, and January 30, based on the respective quarters. Rule 482-1-036-.04
Colorado announced the launch of the Surplus Lines Information Portal (SLIP) for reporting and paying surplus lines premium taxes. The SLIP platform will handle policies and endorsements with effective dates on or after January 1, 2025, while earlier policies will continue using the existing tax system. A 3% premium tax and a 0.175% transaction fee will apply, with payments processed via ACH Debit. Premium taxes and fees must be reported within 30 days of the transaction's effective date. Notice dated 12/3/24
Montana published a list of eligible surplus lines companies that surplus lines insurance producers in the state may place insurance with. The NAIC has renamed the list to "Quarterly Listing of Alien Insurers, and a link to access the list is provided in the notice. Eligible Surplus Lines List dated December 13, 2024
Pennsylvania's Insurance Department announced that the Surplus Lines law required adjustment to the Exempt Commercial Purchaser Minimum Qualifying Amounts effective January 1, 2025. These adjustments, based on the Consumer Price Index from June 2019 to June 2024, comply with insurance Section 1610 which mandates a review every five years. Stakeholders can direct inquiries about these adjustments to the Office of Corporate and Financial Regulation. Notice 2024-19
West Virginia announced an update to the Surplus Lines Export List, which streamlines the process of exporting specific insurance coverages to the surplus lines market. This update, covering sectors like Agriculture, Aviation, and Medical Malpractice, allows certain coverages to bypass the diligent search requirement among admitted insurers. The notice also highlights regulations on surplus lines brokers, the 4.55% surplus lines tax rate, and guidance for obtaining a non-resident surplus lines broker’s license. Notice dated 12/17/24
WORKERS' COMPENSATION
Arizona Industrial Commission announced the current average monthly wage statutory maximum. The wage maximum is $5,906.55 for injuries occurring from January 1, 2025, to December 31, 2025. Compensation and death benefits are typically based on the employee’s average monthly wage at the time of injury, with the maximum amount set by statute and periodically amended by the Legislature. Notice of Monthly Benefit dated 1/1/25
California's Division of Workers' Compensation advises employers and health care professionals to be vigilant for work-related bird flu cases, particularly among dairy farmworkers and commercial poultry workers, following outbreaks in poultry flocks. Workers who contract bird flu while employed are eligible for workers' compensation benefits, and employers must provide claim forms and guide employees to knowledgeable health care providers. DWC Release 2024-114
California's Division of Workers' Compensation updated the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) section of the Official Medical Fee Schedule, effective January 1, 2025. This aligns with the Medicare January 2025 annual DMEPOS Fee Schedule update. DWC Release 2024-110
California's Division of Workers' Compensation reminds claims administrators about the mandatory submission of the Annual Report of Inventory (ARI) for claims reported during calendar year 2024, due by April 1, 2025. The ARI must detail the number of claims reported at each adjusting location for the previous year, even if no claims were reported, and be submitted to the DWC Audit Unit. Claims administrators must report any changes to the ARI within 45 days of the change. DWC Release 2025-01
California's Division of Workers' Compensation updated the Official Medical Fee Schedule for pharmaceuticals, effective July 1, 2025, impacting the maximum reasonable fee for pharmaceuticals dispensed to injured workers. The changes align the fee schedule with the Medi-Cal pharmacy payment system. DWC Release 2024-108
Delaware's Compensation Rating Bureau Inc. (DCRB) along with 9 other Bureaus released an updated study titled "Countrywide Mega Claims: Accident Years 2001-2021." The study examines claims exceeding $2 million, $3 million, $5 million, and $10 million, highlighting their growing frequency and substantial impact on loss dollars, which now surpass $1 billion annually. The study reveals that mega claims account for less than 1% of total claims but represent over 2% of total loss dollars. DCRB Circular 1046
Indiana requires entities to submit the first installment of their 2024 Second Injury Fund assessment by January 31, 2025, using the state's electronic payment system. Circular 2024-10
New Jersey's Division of Workers' Compensation adjusted the maximum workers' compensation benefit weekly rate for temporary disability, permanent total disability, permanent partial disability, and dependency. The change applies to injuries occurring in the calendar year 2025. NJAC 12:235-1.6
Oklahoma's Insurance Department announced a 9.2 percent decrease in workers' compensation insurance loss costs for 2025, effective for new and renewing policies starting January 1, 2025. Notice dated 12/10/24
Newsletter
Life and Health News April 2025
Life and Health News
April 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!
ACTUARIAL
Idaho issued guidance requiring all authorized insurers to adopt the revised NAIC Accounting Practices and Procedures Manual and Valuation Manual for preparing their 2025 quarterly and annual financial statements. Insurers offering life insurance, accident and health insurance, annuity contracts, and deposit-type contracts must use the January 1, 2025, edition of the Valuation Manual for reserve calculations. Bulletin 25-01
AGENT / PRODUCER LICENSING AND APPOINTMENT
Arkansas updated the company appointment renewal process for producers, requiring licensed entities to file annually under the Producer License Model Act. Appointment renewals must be completed by May 24, 2025, and terminations submitted by the same date via NIPR. Renewals will be accepted from June 1 to June 30, 2025. Bulletin 3-2025
New Mexico's Office of the Superintendent of Insurance (OSI) announces the transition to an online procedure for reporting name changes for individuals and business entities. Name changes must be submitted through www.NIPR.com, with a $50 penalty for late submissions. Notice - Licensees Name Change
West Virginia's Offices of the Insurance Commissioner announced that company appointment renewals for producers will be processed through the National Insurance Producer Registry (NIPR) starting June 6, 2025. A $25 renewal fee per individual per company is due August 31, 2025, after which appointments will be canceled. Non-payment will result in terminations effective May 31, 2025. Notice Dated 3/18/25
ARTIFICIAL INTELLIGENCE
Wisconsin's Office of the Commissioner of Insurance (OCI) issued a bulletin requiring insurance entities to ensure their use of Artificial Intelligence (AI) complies with existing legal frameworks, particularly around unfair trade practices and discrimination. The bulletin outlines OCI's expectations for AI development and deployment, emphasizing the creation of a written AI System Program with governance, risk management, and internal audit controls to mitigate consumer risks. It also sets guidelines for engaging with third-party AI systems and details the documentation OCI may request during audits. Bulletin Dated 3/18/25
CLAIMS / CLAIMS ISSUES
New Hampshire issued a bulletin clarifying the limitations on health carriers' ability to retroactively collect reimbursements from healthcare providers, emphasizing that claims settled for more than 12 months cannot be denied retroactively, except under specific conditions. The bulletin reminds carriers of the statutory requirements for retroactive denials, including providing a written explanation and advance notice, and highlights the importance of proper coordination of benefits and the use of federal denial reason codes in communications with providers. Bulletin INS 25-021-AB
CONFIDENTIALITY / PRIVACY
Kentucky amended its Consumer Data Protection Act to clarify the scope and exemptions of consumer data privacy regulations, including health-related information and research data. The amendments also expand the requirements for data protection impact assessments, now covering profiling activities that are deemed "unlawful" in addition to those that pose a risk of unfair treatment or disparate impact on consumers. HB 473
DISCRIMINATION
Iowa amended its laws to align legal definitions and protections with biological sex at birth, removing "gender identity" from protections against discriminatory practices in credit transactions. This means protections against discrimination in consumer credit, loans, and insurance offerings will no longer explicitly cover gender identity. SF 418
ELECTRONIC TRANSACTIONS
Colorado now allows for the electronic delivery of health coverage plan information and documents. The law mandates standardized health benefit plan identification cards in both printed and electronic formats, and requires carriers to obtain consent before delivering notices electronically. It also permits health plans to be posted on carriers' websites, with specific consent and conditions for access. SB 10
FILINGS: HEALTH
Illinois issued a bulletin providing guidance to health insurance issuers on the submission deadlines for small group ACA quarterly rate filings for the third and fourth quarters of the 2025 plan year. Issuers must submit rate changes by March 18, 2025, for rates effective July 1, 2025, and by June 18, 2025, for rates effective October 1, 2025. The DOI will publish non-proprietary portions of these filings and initiate 30-day public comment periods on March 25, 2025, and June 25, 2025. Bulletin 2025-03
Missouri's Department of Insurance issued a bulletin detailing the health insurance rate filing requirements for the 2026 plan year. Health carriers must submit rates based on the assumption that the expanded eligibility for Advanced Premium Tax Credits (APTCs) will expire, with the filing deadline set for June 4, 2025. The bulletin also provides specific guidance on pricing factors, Cost Sharing Reduction (CSR) adjustments, and induced demand factors. A Notice was also issued providing ACA health rate filing guidelines for plan year 2026. Bulletin 25-01 and Notice dated March 14, 2025
Virginia issued guidance regarding the submission of insurance products and premium rates for approval, outlining updated filing requirements and deadlines for carriers licensed to sell accident and sickness insurance, health maintenance organizations, and dental plans in Virginia. The initial filing deadline is April 18, 2025, with the first transfer deadline on July 1. SCC Notice Dated 3/7/25
HEALTH CARE EXCHANGE / MARKETPLACE
Arkansas issued a bulletin to guide health insurers in preparing Plan Year 2026 individual, on-Marketplace rate filings, requiring two sets of rates based on the potential expiration or continuation of ARPA expanded tax credits. The bulletin introduces a standardized method for applying a Cost Sharing Reduction (CSR) load to On-Marketplace Silver plans and mandates detailed documentation of the impact on rates, enrollment, and revenue. Bulletin 4-2025
Delaware published guidance for qualified health plan (QHP) rate filings for the 2026 Plan Year, requiring insurers to submit two sets of rates - one assuming the expiration of ARPA premium tax credits by December 31, 2025, and another assuming their extension through December 31, 2026. Insurers must provide actuarial memoranda to explain the rate adjustments for each scenario, with all filings due through the SERFF system by July 2, 2025. Domestic-Foreign Bulletin 149
HEALTH INSURANCE / HEALTH RATES
Delaware issued a bulletin providing updated guidance on completing the 2026 Affordability Standards Data Submission (ASDS) template for health benefit plan rate filings. Insurers must ensure compliance with Regulation 1322 by submitting the updated ASDS template, including new codes for primary care and care management services, by June 20, 2025, for individual and small group plans and September 19, 2025, for large group plans. Additionally, carriers must reimburse providers at Medicare rates for specific services and adhere to the 5.50% price trend cap for medical services. Domestic-Foreign Insurers Bulletin 138 (Revised)
Illinois' Insurance Department (DOI) issued an update for health insurance issuers regarding applied behavior analysis licensure. The DOI informs issuers that Behavior Analysts and Assistant Behavior Analysts are now included in the CORE licensing system, with a grace period for licensure delays extending until April 21, 2025. Bulletin 2025-04
Mississippi extended its provision requiring health insurance and employee benefit plans to cover telemedicine services to the same extent as in-person consultations. This extension applies until the statute is repealed on July 1, 2028. SB 2415
Texas amended regulations governing Health Maintenance Organizations (HMOs), addressing issues such as balance billing protections, mandatory disclosures, and physician contracts. The amendments clarify HMO responsibilities for out-of-network claims, improve physician directory requirements, and update contractual provisions for group and individual agreements. 28 TAC s 11.506
HOLDING COMPANIES
Idaho amended its Holding Company Law to include Group Capital Calculation instructions and NAIC liquidity stress test frameworks, among other changes. HB 71
Mississippi amended its Holding Company Act to include NAIC group capital calculation and liquidity stress test requirements. The amendments revise the registration and reporting requirements for insurers, establish confidentiality provisions, and clarify regulatory requirements for transactions within holding company systems. SB 2412
North Dakota amended regulations governing insurers within insurance holding company systems. The changes include new definitions, annual group capital calculation filings, and requirements for liquidity stress tests. The amendments also set standards for transactions within insurance holding companies, ensure adequate insurer surplus, and establish strict confidentiality protocols for investigative materials and financial assessments. HB 1124
INTERNAL AND EXTERNAL REVIEW
Kentucky's Department of Insurance (DOI) issued a Notice outlining the requirements for insurers to establish an external review process to resolve disagreements between covered persons and insurers regarding adverse determinations. The notice mandates insurers request external reviews through the DOI's eServices, ensuring no conflict of interest with the assigned Independent Review Entity (IRE), and provides procedures for assignment, notification, and reassignments when necessary. Notice Dated 3/13/25
MISCELLANEOUS HEALTH / ACCIDENT
Illinois' Insurance Department issued guidance for health and dental carriers and HMOs requiring self-audits of each provider directory at least every 90 days and submit a report to the Department. In addition, each online provider directory must be updated monthly within 2 business days after being notified of a change by a participating provider. Failure to update a directory as prescribed may result in fines. Bulletin 2025-05
South Dakota released a bulletin outlining new compliance requirements for Enhanced Direct Enrollment Entities (EDEs), health insurance issuers, and producers. The bulletin mandates that EDEs secure both a third-party administrator and insurance producer license, prohibits working with unlicensed entities (except federally certified Navigators), and requires health insurance issuers to appoint any EDE they compensate. Insurance producers must also be licensed and appointed by the issuer to use an EDE for consumer enrollment. Bulletin 25-01
MISCELLANEOUS LIFE / ANNUITY
Michigan's Department of Insurance (DOI) issued a bulletin updating the maximum amount for cemetery or funeral predeath assignments under section 500.2080 of the Insurance Code. Bulletin 2025-01-INS
PHARMACY BENEFIT MANAGERS
Arkansas enacted the Pharmacy and Pharmacist Timely Reconciliation and Payment of Pharmacist Services Act to regulate pharmacy benefits managers (PBMs) and the processing of pharmacy claims. The law introduces new definitions, mandates timely payment for clean claims, and requires PBMs to notify pharmacies of claim issues within specified time frames, with penalties for late payments. HB 1620
PREMIUM TAX
Wisconsin's Office of the Commissioner of Insurance announced the adoption of the OPT/ns system for submitting and paying Wisconsin premium taxes, fire department dues, and fees. Insurers must use this system for all premium tax payments, with a $17.50 non-refundable transaction fee applied. Bulletin Dated 2/27/25
REGULATORY REPORTING REQUIREMENTS
New Hampshire's Department of Insurance (DOI) informs health carriers and related entities about a delay in the enforcement of certain filing requirements, including utilization review filings, market conduct annual reports, and certificates of compliance regarding advertisements. The DOI will not enforce compliance for filings due on April 1, 2025, and April 1, 2026, but will provide guidance and templates for subsequent submissions due in 2027 and beyond. Bulletin INS 25-024-AB
REPORTS - DATA CALLS & OTHER REPORTS
Arkansas updated the reporting process for Rule 128 submissions, extending the review period from 20 to 60 business days due to a high volume of reports. If a report is incomplete or deficient, submitters will be notified and given 10 business days to correct and resubmit it. Bulletin 2-2025
Pennsylvania issued guidance on the Medicare Supplement Data Call, requiring insurers to submit annual refund calculation data for Medicare Supplement benefit plans by May 31, 2025. Insurers must use designated Excel worksheets for reporting, ensuring accurate Type of Insurance (TOI) and Sub-Type of Insurance (Sub-TOI) codes, with filings submitted through SERFF. 2025 Medicare Supplement Data Call
THIRD PARTY ADMINISTRATORS
Puerto Rico adopted Rule 111 amending the licensing process for third-party administrators. The rule mandates that entities operating as third-party administrators in Puerto Rico must obtain a license, complete the Uniform Application, and pay a $2,500 annual fee, with a 30-day submission deadline for existing administrators. Insurers must ensure all administrators are properly licensed. Ruling CN-2025-369-SR
TRADE PRACTICES
Massachusetts adopted new rules to prevent unfair and deceptive practices in marketing, solicitation, and sale of products, including trial offers and contracts with negative option features. The regulation mandates clear and conspicuous disclosure of total prices, prohibits misleading fees, and requires straightforward cancellation mechanisms for trial offers. 940 CMR 38.01
UNCLAIMED PROPERTY
Idaho updated its Unclaimed Property Law to clarify when certain properties, including amounts owed by insurance companies, are presumed abandoned. HB 165
South Dakota updated the Uniform Unclaimed Property Act to include provisions for virtual currency and related notice requirements. The act defines virtual currency, mandates liquidation or notification of unclaimed digital assets, and clarifies the process for reporting and managing abandoned property. It also revises the definition of "last known address" and introduces new notice and reporting rules for holders of unclaimed property. HB 1196
- Category
- All
- Article
- Download
- Year
- 2026
- Archive
- All Dates