State Updates: Tri-Agency Rule Fixed Indemnity Notice

The Tri-Agency Rule, finalized by the Departments of Health and Human Services, Labor, and the Treasury, includes notice requirements for Fixed Indemnity insurance policies.

If you remember from our previous blog, the notice applies to both new and existing coverage with a plan year (group)/coverage period (individual) beginning January 1, 2025 and must display prominently on the first page (in either paper or electronic form, including on a website) of the materials listed below in at least 14-point font:


Individual Market  

  • marketing, application, and enrollment (including reenrollment) materials

  • policy, certificate, or contract of insurance

Group Market  

  • marketing, application, and enrollment (including reenrollment) materials

 

The required language of the notice is shown below:


The Tri-Agency Rule also includes notice requirements for Short-Term, Limited-Duration (STLDI) insurance policies and limitations on the duration of any newly issued STLDI plan, which are effective September 1, 2024.



With the September and January deadlines approaching, states are starting to issue directives regarding this final rule.




Alabama issued Bulletin 2024-02 requiring carriers to submit revised forms and rates for review, effective immediately.


Iowa issued Bulletin 24-01 indicating carriers are expected to make all necessary changes to comply with the required federal changes.

Kansas provided notice via SERFF indicating carriers should update existing STLDI forms to comply with the required federal changes.

We anticipate more states will provide directives in the coming weeks and will keep you updated.

Telos Actuarial can help you update your forms to include the required notice and submit to states where required.  Contact us to find out more.

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