COVID-19 Daily Insurance Regulatory Updates to Keep You Informed During the Lockdown (April 14th, 2020)
April 14, 2020

In conjunction with the Locke Lord COVID-19 task force, we are reviewing, analyzing, and compiling regulatory updates to provide clients easy access to information during this unprecedented time. If you have any questions on the subject matter below, do not hesitate to reach out. The information below relates to state and federal bulletins, emergency orders, pending/enacted legislation, and other related actions taken in response to the COVID-19 pandemic.

All Lines of Insurance

D.C.: On April 9th, The Department of Insurance, Securities and Banking issued Interpretive Guidance on Mayor’s Order 2020-053 relating to the closure of non-essential businesses and prohibition on large gatherings during COVID-19 pandemic. The guidance provides a definition of essential businesses, and reminds essential businesses to continue practicing social distancing. Insurance companies and personnel are considered essential.

Kentucky: On April 13th, Governor Andy Beshear signed House Bill 356 into law, authorizing the Chief Justice of Kentucky, for the duration of the Governor’s declaration of a State of Emergency, to declare a Judicial Emergency which extends any administrative actions deadlines, and statutory timelines and statutes of limitations for court filings and proceedings.

Maryland: On April 14th, the Maryland Insurance Administration (“Insurance Administration”) issued an FAQ during the COVID-19 emergency. The FAQ covers examination and audit unit FAQs, filing deadline extensions, electronic filings and wet signatures, and litigation filings.

Michigan: On April 13th, Michigan issued Bulletin 2020-15-INS, which provides that Michigan will issue temporary producer licenses to applicants meeting the requirements for licensure under existing statute, without requiring examination. Temporary producer licenses will be issued for a period of 90 days or until 30 days after the cessation of the current state of emergency related to COVID-19, whichever is later, not to exceed 180 days. Temporary producer licenses will automatically expire 90 days after issuance or 30 days after the state of emergency is lifted by the Governor, whichever is later. Additional conditions are identified in the Bulletin.

Missouri: On April 13th, the Missouri Department of Commerce and Insurance (the “Department”) issued Insurance Bulletin 20-09 authorizing the issuance of a temporary resident insurance producer license for life, variable life and variable annuity, accident and health, property, casualty, personal lines and crop. The Department will temporarily waive the licensing requirements of successfully passing an examination for those lines of business provided a currently licensed Missouri insurance producer will sponsor the applicant. According to the Bulletin, in order to apply for a temporary license, the Department must receive a completed application, a completed temporary license questionnaire (the temporary license questionnaire is attached to the Bulletin) and a $100 nonrefundable license fee. Both the completed application and the temporary license questionnaire must be emailed to Upon receipt of the application and questionnaire, the Department will provide a web link to applicants to use to send the electronic payment of the $100 nonrefundable license fee. Forms for Temporary Missouri Resident Insurance Producer License can be found at

New Jersey: On April 10, the NJ Department of Banking and Insurance issued a press release directing Insurers to provide an emergency grace period for payment of insurance premiums for residents and businesses amid COVID-19. Following the Executive Order, the Department directed health and dental insurance carriers in the individual market, small group and large group markets to provide a grace period for premium payments of at least 60 days. The Department directed issuers of life insurance policies, property and casualty policies and insurance premium finance companies to provide a grace period for payments of at least 90 days. Consumers must contact their insurance company to take advantage of the emergency grace period and to discuss options to pay their premiums over time after the grace period ends.

North Carolina: On April 14th, the North Carolina Department of Insurance issued guidelines for submitting COVID-19 fillings for benefits to North Carolina consumers.

Tennessee: On April 13th, Governor Bill Lee issued Executive Order No. 27, an order extending temporary social distancing and stay-at-home provisions of Executive Order Nos. 17, 21, 22, and 23 from April 14, 2020 until 11:59pm CDT on April 30, 2020.

Texas: On April 13th, the Texas Department of Insurance, Division of Workers’ Compensation (DWC), adopted emergency rule, 28 TX ADC 167.1 building upon the existing telemedicine and telehealth rules by creating an exception to current CMS distant site practitioner requirements. The emergency rule allows health care providers licensed to perform physical medicine and rehabilitation services, including physical therapists, occupational therapists, and speech pathologists, to bill and be reimbursed for services currently allowed under CMS telemedicine and telehealth billing codes. The rule went into effect on April 13, and expires in 120 days unless it is extended for another 60 days.

Property and Casualty Insurance

Alabama: On April 8th, Commissioner Jim Ridling issued Bulletin 2020-06, urging all Alabama auto insurers to consider offering an immediate reduction in premium to reflect the reduced exposure. The Bulletin states this can be accomplished through premium credit or return of premium and may be implemented immediately. Additionally, the Bulletin states, “[p]rospective reductions in premium or retroactive return of premium will not be considered a rebate or unfair discrimination to the extent they are reasonable and consistently applied.”

Maryland: On April 13th, the Maryland Insurance Administration (“Insurance Administration”) issued Bulletin 20-20, seeking the full cooperation of all property and casualty insurers writing commercial policies in the State with respect to policies rated using estimated payroll / revenue, short-rate penalty policy provisions, use of credit for underwriting, and COVID-19 claim inquiries.

Montana: On April 13th, Commissioner Matthew Rosendale, Sr. issued an update to the April 9th Informational Bulletin on rate filings. The April 9th Bulletin addressed how insurance companies were required to provide rate filings and form filings to issue premium refunds/discounts/credits. The updated Bulletin, issued to all property and casualty insurers who have issued or intend to issue COVID-19 related premium refunds/discounts/credits, amends the April 9th Bulletin to state that “Insurers are NOT required to submit a form filing for premium refunds, discounts or credits issued based upon industry-related impacts due to COVID-19.”

South Carolina: On April 14th, the South Carolina Workers’ Compensation Commission issued an Advisory Notice regarding the assessment of fines and penalties. The Notice advises all interested parties that the Commission will reactivate the assessment of fines and penalties for failure to file required reports on May 1, 2020.

Health Insurance

Puerto Rico: On April 8th, the Office of the Commissioner of Insurance (“OCI”) issued Ruling Letter No. CN-2020-275-D. On March 30, 2020, OCI issued Ruling Letter Number CN-2020-272-D, which sought to establish an expedited procedure for certain medical claim payments needed to defray increased operational costs during the health emergency arising from COVID-19 in Puerto Rico. Due to operational challenges, through Ruling Letter No. CN-2020-275-D, OCI has repealed Ruling Letter Number CN-2020-272-D.

Puerto Rico: On April 8th, OCI issued Ruling Letter No. CN-2020-274-D, which clarifies that telemedicine coverage mandated under Puerto Rico’s Joint Resolution 19-2020 must be provided in accordance with existing mental health parity requirements. It also states that OCI “requires that all health services organizations and insurers that write commercial health insurance and Medicare Advantage honor the payment of services rendered by health services providers, whether physical or mental health, through the use of telemedicine at the same rate as if the service were provided face to face. No reduction in the payment of fees for health care service providers will be allowed on the sole grounds that the mechanism that was used was telemedicine.”

Visit our COVID-19 Resource Center often for up-to-date information to help you stay informed of the legal issues related to COVID-19.

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