COVID-19 Daily Insurance Regulatory Updates To Keep You Informed During The Lockdown (June 15, 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

Connecticut: On June 12, the Connecticut Insurance Department (“CID”) issued Bulletin FS-40, advising all domestic insurers, domestic health care centers or domestic fraternal benefit societies of certain flexibility with regulatory requirements during the COVID-19 public health emergency. The CID states that this flexibility is being provided in part to recognize that it and other states anticipate using additional targeted information requests to gather more specific information and the industry’s prompt attention to those matters is appreciated. The Bulletin discusses compliance with certain hard copy filing requirements, Forms D and D-1 Seal in light of COVID-19.

Connecticut: On June 12, the CID issued Bulletin FS-41, advising all licensed foreign insurers, foreign health care centers or foreign fraternal benefit societies of certain flexibility with regulatory requirements during the COVID-19 public health emergency. The CID states that this flexibility is being provided in part to recognize that it and other states anticipate using additional targeted information requests to gather more specific information and the industry’s prompt attention to those matters is appreciated.

Pennsylvania: On June 13, the Pennsylvania Insurance Department (Department) issued Notice 2020-16, to provide guidance related to in-person operations and sales for insurance licensees in counties moving to the green phase of reopening. The Notice states that telework and remote operations are strongly encouraged in counties that have been designated to move to the green phase, but where that is not feasible, insurance licensees are permitted to conduct in-person operations, including in-person sales, with restrictions to protect licensees and their employees and consumers. Additionally, licensees are advised that in-person business should be conducted by appointment only, wherever possible, when operating in the green phase. Walk-in business is permissible to the extent that the insurance business has enacted mitigation procedures designed to protect employees and the public.

Health Insurance

Utah: On June 10, Commissioner Kiser published Bulletin 2020-7 Addendum, which clarifies 2021 plan year filing submission requirements for health benefit plans. The Addendum provides that due to COVID and rapidly changing rating assumptions affected by COVID, the initial rate flings due June 15, 2020 for small employer and July 1, 2020 for individual will be viewed as preliminary, and will allow insurer driven changes to the rating assumptions up until August 3, 2020.

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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