Life and Health News
December 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!
ADVERTISING / SALES & MARKETING
New Mexico released a bulletin outlining prohibitions on deceptive marketing of excepted benefit plans, replacing Bulletin 2020-013. The OSI warns that portraying excepted benefits as comparable to major medical coverage, including using ACA metal-tier terms, bundling multiple excepted benefits in one sale, misrepresenting benefits, or spoofing caller IDs, is deceptive and subject to penalties. Producers must disclose their name and NPN at first contact. Bulletin 2025-012
AGENT / PRODUCER LICENSING AND APPOINTMENT
California announced that, effective January 1, 2026, the 20-hour prelicensing education requirement for insurance producer license applicants is repealed, while maintaining the 12-hour ethics and California Insurance Code instruction. Notice Dated 11/10/25
Puerto Rico announced updates to licensing exam materials for insurance producers, now requiring candidates for Life, Disability and Health, and Health Care Insurance Producer licenses to use the new Life and Health Insurance License Examination Manual – 2025, First Edition. Candidates testing before year-end may opt into the updated exam by request, and all exams after January 1, 2026, will use the new materials. Circular Letter CC-2025-249-SP
Texas updated its licensing processes for military service members, veterans, and spouses. Amendments include recognition of out-of-state licenses, provisional licensing authority, clarified application and documentation requirements, and updated fee waivers. 16 TAC s 60.501
Wisconsin announced that starting January 6, 2026, all company agent appointment renewals must be processed electronically through NIPR, with invoices available until March 15, 2026. Renewal payments must be made electronically, and unpaid invoices by the deadline will result in termination of all appointments, requiring reappointment and payment of initial fees. Bulletin Dated 11/7/25
CAPTIVES
Alabama clarified that the temporary moratorium on licensing or registration of captive insurance companies does not apply to foreign risk retention group registration applications, which will be processed in the ordinary course. Clarification to Bulletins 2025-01 and 2025-05
CLAIMS / CLAIMS ISSUES
Utah amended its rules so that insurers must list their own contact information before the Department’s on adverse benefit determinations. The update is intended to reduce consumer confusion. Rule R590-192-7
CYBERSECURITY
Delaware warns regulated entities about active phishing scams impersonating the DOI, emphasizing that official communications only come from addresses ending in @delaware.gov or @state.de.us. The DOI advises recipients to avoid clicking links, report suspicious messages, and follow cybersecurity best practices, including multi-factor authentication and staff training, to protect sensitive information. Universally Applicable Bulletin 10
DISASTER / CATASTROPHIC EVENT
Alaska issued a bulletin to ensure fair treatment of consumers affected by the 2025 west coast storms, directing insurers to suspend policy cancellations or non-renewals, extend grace periods, and maintain access to healthcare and prescriptions in impacted areas. The bulletin applies to all lines of insurance and outlines temporary measures to assist both consumers and insurers during the recovery period. Bulletin B 25-08
Arizona issued an Addendum to Bulletin 2025-09 expanding insurer assistance requests to include Mohave County and affected areas of Maricopa County following severe weather emergencies, urging insurers to support policyholders while ensuring relief programs are applied fairly. Bulletin 2025-09 (INS) (Addendum)
DISCRIMINATION
Delaware issued guidance on House Substitute 1 for HB 55 prohibiting unfair discrimination in insurance based on military status. Carriers may not deny, cancel, or modify coverage solely due to military status and must update materials, maintain documentation for any legally permitted distinctions, and ensure marketing, sales, and claims practices comply with the law. Domestic-Foreign Bulletin 161
HEALTH CARE EXCHANGE / MARKETPLACE
Colorado issued a bulletin clarifying that health benefit plans must cover biomarker testing for diagnosis, treatment, and monitoring of diseases or conditions when medically supported, as required by SB 24-124. The guidance applies to large group plans issued or renewed on or after January 1, 2025, and to individual and small group plans within benchmark plan limits. Bulletin B-4.155
Colorado updated its standardized health benefit plans for the individual and small group markets. Changes include reducing the Silver Enhanced Plan actuarial value from 94% to 73% and revising plan applicability across On-Exchange and Off-Exchange markets, along with updates to the regulation’s effective date and history. 3 CCR 702 Reg. 4-2-81
HEALTH INSURANCE - COMPREHENSIVE
Delaware announced the Delaware Pre-Authorization Act of 2025 (SB 12), establishing uniform standards for health-care service pre-authorization effective for policies issued or renewed after December 31, 2026. The Act sets timelines for determinations, qualifications for reviewers, validity periods for pre-authorizations, electronic provider portal requirements, and notice and appeal procedures. Domestic-Foreign Bulletin 163
Illinois issued a bulletin announcing emergency amendments requiring state-regulated health plans to provide no-cost coverage for all vaccines listed in ACIP recommendations or updated IDPH guidelines, including COVID-19 immunizations. The bulletin clarifies filing requirements for issuers, outlines exceptions for grandfathered and excepted benefit plans, and preserves existing 2025 immunization coverage standards without requiring rate revisions. Bulletin 2025-18
Nebraska announced the release of two new standardized prior authorization forms for health services, drug benefits, and durable medical equipment, effective January 1, 2026, for fully insured plans. These forms implement LB 77, which requires accessible criteria, clear review timelines, and prohibits AI-only denials, with self-insured and ERISA plans excluded. Notice Dated 11/18/25
HIV
Arkansas updated its HIV testing protocols for insurers to align with CDC recommendations, replacing the outdated Western blot method with more accurate screening, supplemental, and nucleic acid tests. The update applies to life, health, and other insurers and ensures compliance with nondiscrimination standards. Bulletin 15-2025
IIPRC / INTERSTATE COMPACT
Oregon released a rule opting out of two Interstate Insurance Product Regulation Compact Uniform Standards after determining they do not provide sufficient consumer protection. The new rule declines Oregon’s participation in the standards for Individual Deferred Index-Linked Variable Annuity Contracts and for Market Value Adjustment Features for Modified Guaranteed and Index-Linked Variable Annuities. OAR 836-080-0195
LIMITED BENEFIT CONTRACTS
Virginia issued guidance on filing, disclosure, benefit, and duration requirements for Short-term Limited-duration Insurance (STLDI) under state law, including a three-month maximum term and six-month annual limit. The document outlines mandatory notices, benefit standards, pre-existing condition rules, and applicability of group market requirements. SCC Notice Dated 10/31/25
MISCELLANEOUS
Colorado updated FAMLI Act regulations, clarifying private plan requirements, streamlining employer obligations, and confirming that private plan benefits are exempt from state income tax. The updates revise rules on plan payments, information-sharing, application submission, and review processes, including penalties for noncompliance or failure to incorporate Division-issued addendums. 7 CCR 1107-5
Colorado updated its uniform prescription drug prior authorization and appeals process for all health benefit plans. The amendments establish standardized electronic forms, define prior authorization procedures for urgent and non-urgent requests, extend approval durations to at least one year, and prohibit prior authorization for certain FDA-approved medications, including Medication-Assisted Treatment and chronic maintenance drugs, while clarifying carrier notification requirements to providers and covered persons. 3 CCR 702 Reg. 4-2-49
Kansas issued a notice providing the Commissioner-set fees applicable from January 1 through December 31, 2026, outlining licensing, registration, filing, and certification fees. Notice of Fee Amounts 2026
REPORTS - ANNUAL / QUARTERLY STATEMENT
Oregon issued a regulation effective January 1, 2026, updating insurer reporting requirements to enhance transparency in prior authorization and grievance reporting. The rule adjusts reporting deadlines, adds statutory definitions, and requires more detailed metrics for both standard and expedited prior authorizations. OAR 836-053-1070
TRADE PRACTICES
Delaware issued a bulletin emphasizing that unfair trade practices in marketing Medicare Advantage and Medicare Supplement plans violate state law and may conflict with federal guaranteed availability protections. The DOI emphasizes that carriers and producers must market approved products in good faith, honor filed compensation structures, and ensure consumer access, with violations subject to enforcement actions. Producers and Adjusters Bulletin 39
Mississippi addressed unfair trade practices in marketing Medicare-related insurance products, emphasizing compliance with the state’s Unfair Trade Practices Act. The bulletin prohibits actions that restrict consumer access or manipulate the market and requires carriers to ensure fair competition and good-faith marketing to Medicare-eligible individuals. Bulletin 2025-7
New Hampshire issued a bulletin addressing unfair trade practices in the marketing of Medicare Advantage and Medicare Supplement products, citing concerns such as withholding enrollment materials, discouraging producers, and altering compensation midyear. The DOI reminds carriers and producers that these practices may violate state law and federal MA compensation rules, and emphasize duties of good faith, consistent compensation, and accessible enrollment materials. Bulletin INS 25-082-AB
North Dakota warns insurers and producers of prohibited enrollment and compensation practices in the Medicare market, including limiting access to applications, discouraging sales, altering compensation, or enrolling consumers for higher commissions. The Department reminds carriers and producers that such conduct violates North Dakota law and urges duties of good faith, product suitability, and consistent, approved compensation. Bulletin 2025-2
Oklahoma issued a bulletin warning health insurers that restricting access to Medicare-related products, discouraging producer sales, or altering or eliminating commissions may violate laws regarding unfair or deceptive practices. The DOI stresses that enrollment materials must remain accessible, compensation must be consistent with filed rates unless a plan was expressly filed as zero-commission, and artificial market manipulation that harms Medicare-eligible Oklahomans is prohibited. Bulletin 2025-12
South Carolina reminds insurers and producers that restricting access to Medicare, Medicare Advantage, or Medicare Supplement plans is considered an unfair trade practice under South Carolina law. Insurers must ensure approved products remain accessible through customary channels and honor filed compensation structures, with enforcement actions possible for violations. Bulletin 2025-10
UTILIZATION REVIEW - HEALTH CARE
Colorado amended its standards for prospective, retrospective, and urgent prior authorization reviews while clarifying internal claims and appeals processes for health benefit plans. Key changes include extended validity of prior authorizations to one year, refined notification timelines, detailed approval and denial requirements, and provisions for covering additional or related procedures during surgical or urgent care. 3 CCR 702 Reg. 4-2-17
Connecticut released a notice to health insurers and related entities updating its guidance on adverse determination notices to reflect approved language for children’s mental health and updated URLs on the Office of Healthcare Advocate website. Notice Dated 11/12/25