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