Life and Health News
March 2026
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!
AFFORDABLE CARE ACT
Maryland published a bulletin providing guidance on filing requirements for individual and small employer health and stand-alone dental plans for the 2027 ACA policy year. The bulletin sets deadlines for forms and rate submissions, specifies required documentation including actuarial value, prescription drug benefit certifications, MHPAEA compliance, and Unified Rate Review Templates, and clarifies that essential health benefits remain unchanged except for presumptively discriminatory benefits. Bulletin 26-6
United States Centers for Medicare and Medicaid Services issued guidance for 2027 ACA payment parameters, setting the premium adjustment percentage at 89.2%, the maximum annual cost-sharing limits at $12,000 for self-only and $24,000 for other coverage, and the required contribution percentage for affordability exemptions at 8.50%. NHEA projections and ACA rules are used to determine cost-sharing, employer responsibility payments, and eligibility for catastrophic coverage. CMS Notice Dated 1/29/26
United States Centers for Medicare and Medicaid Services released the key operational dates for 2026, covering Qualified Health Plan (QHP) certification, rate review, form review, and risk adjustment. Major deadlines include QHP applications, rate justifications and determinations, form filings, and risk adjustment submissions and payments, with Open Enrollment and public quality ratings starting November 1, 2026. CMS Notice Dated 2/23/26
CAPTIVES
Utah amended its rules for captive insurers, moving the Statement of Actuarial Opinion filing deadline to June 30 to align with the annual audit and clarifying that the Statement of Economic Benefit to the State of Utah must be included in the annual report. The rules specify that both the audit and actuarial opinion are part of the company’s annual financial condition report. R590-238-4
Vermont released guidance on credit for reinsurance for captive insurers, detailing requirements for recognizing reinsurance recoverables, transferring risk to qualified reinsurers, and maintaining sufficient security to ensure claims are paid. The bulletin clarifies filing obligations, approval processes for structural changes or affiliated reinsurers, and compliance expectations for both statutory and GAAP filers, while discontinuing the Captive Division’s published list of authorized reinsurers for years ending December 31, 2025, and beyond. Notice Dated 1/28/26
CYBERSECURITY
Delaware reissued a bulletin to remind insurance entities of their obligations under the Delaware Insurance Data Security Act. The Act requires insurers, producers, brokers, agents, underwriters, and contractors to implement information security programs, oversee third-party providers, investigate cybersecurity events, notify the DOI within three business days, and provide impacted consumers with one year of free credit monitoring. Universally Applicable Bulletin 5 (Reissued)
New York released a cybersecurity advisory warning regulated entities of an active vishing campaign in which attackers impersonate IT help desk staff, use spoofed caller IDs, and direct employees to malicious login pages to capture credentials and MFA codes. DFS urges entities to strengthen defenses through identity verification, targeted training, access management, MFA enrollment, and continuous monitoring. Suspected incidents should be investigated and reported to both the FBI’s Internet Crime Complaint Center and DFS. Industry Letter Dated 2/6/26
DENTAL INSURANCE
New Mexico established new dental provider credentialing requirements, applying to all dental health insurance carriers offering network-based individual or group plans. The rules cover initial and re-credentialing, timely payment for covered services, claim submission and coding standards, and a uniform dispute resolution process, while clarifying that carriers are not required to credential providers, set reimbursement rates, or interpret member contracts. 13.10.37.1 NMAC
North Dakota published a bulletin explaining dental loss ratio reporting requirements, applying to all insurers with dental experience in the individual, small group, and large group markets. Insurers must submit annual reports through SERFF by April 30, with 2026 filings covering 2024–2025 data, using separate Excel spreadsheets for each market that include policyholder counts, member months, DLR numerator and denominator, dental loss ratios, and total aggregate expenses. Bulletin 2026-1
DRUG / PRESCRIPTION COVERAGE
West Virginia clarified that prescription drug rebates must be applied at the point of sale to reduce individual cost sharing and that any excess rebates must lower plan premiums rather than being retained by PBMs. The issued bulletin explains insurer filing requirements to show how rebates affect rates, summarizes rebate impacts for 2024–2026 plan years, and reiterates compliance with the Pharmacy Audit Integrity Act amendments. Bulletin 2026-01
FILING REQUIREMENTS / PROCEDURES
Mississippi issued a bulletin establishing the Product and Rate Filing Fee Schedule for expedited review of life, credit life, annuity, and accident and health insurance filings. The bulletin provides detailed fees based on the degree of analysis required, ranging from $215 for low-complexity filings to $1,675 for extremely high-complexity filings, with specific classifications for individual and group policies, riders, annuities, and accident and health forms. Insurers opting for expedited review must adhere to the schedule in Section 2 and Exhibit “A.” Bulletin 2026-2
FILINGS: HEALTH
South Carolina’s Department of Insurance now requires all Medicare Supplement rate filings effective March 4, 2026, and later to include a new Excel exhibit, which is available on the Department’s website. Notice Dated 2/19/26
HEALTH CARE EXCHANGE / MARKETPLACE
Oklahoma announced its transition to a State-based Exchange on the Federal Platform (SBE-FP) starting May 1, 2026, with a full State-based Exchange (SBE) launching for the 2028 plan year. During the SBE-FP period, HealthCare.gov will continue to handle enrollment while Oklahoma assumes functions such as plan management, consumer assistance, marketing, and hotline operations, with full control of all Exchange operations expected in 2028. Notice Dated 2/10/26
HEALTH INSURANCE - COMPREHENSIVE
California issued guidance clarifying large group renewal notice requirements under the Health and Safety Code to ensure timely and transparent disclosure of premium rate and coverage changes. The guidance requires plans to provide renewal notices at least 120 days before renewal, include specific rate comparison information, and inform contract holders of their right to request a rate review within 60 days. DMHC APL 26-003
Connecticut requires health carriers to comply with section 8 of Public Act 25-167 regarding credit for certain out-of-pocket prescription drug purchases. The requirement applies to individual and group health policies issued or renewed on or after January 1, 2026, and takes effect July 1, 2026, mandating that carriers credit qualifying direct payments to licensed providers toward in-network cost sharing. Carriers must also publish a proof of payment form and provide annual instructions to insureds for submitting eligible claims. Notice Dated 2/17/26
Michigan released guidance on the annual deductible adjustment for Qualified Health Coverage under Public Acts 21 and 22 of 2019. The bulletin explains that the Director adjusts the maximum deductible based on changes in the medical component of the Consumer Price Index, but only if the adjustment meets a $500 threshold. For July 1, 2026, through June 30, 2027, the maximum deductible for QHC remains $6,579. Bulletin 2026-08-INS
HOLDING COMPANIES
Alabama adopted new regulations to incorporate the NAIC’s group capital calculation framework for insurance holding company systems. The regulation allows the lead state commissioner to grant exemptions or accept limited filings based on specified premium thresholds, organizational structure, and risk factors. It also establishes standards for recognizing and accepting group capital calculations from qualifying non-U.S. jurisdictions through regulatory acknowledgment and information-sharing agreements. Reg. 482-1-055-18.2
Ohio updated its insurance holding company system regulations, amending rules governing acquisitions (Form A), annual registration and reporting (Forms B, C, and F), affiliated transactions (Form D), managing general agent licensing, examination work paper definitions, and ceding insurer reinsurance credit. The changes aim to enhance transparency, financial stability, and policyholder protection while aligning with NAIC model regulations and statutory requirements. Rule 3901-3-01
Virgin Islands' Division of Insurance and Financial Regulation issued a bulletin providing interim guidance on compliance with Act No. 9073, which amends the Insurance Holding Company System Regulatory Act to require group capital calculations, liquidity stress testing, and receivership provisions. The bulletin outlines filing deadlines, exemptions, recognition of non-U.S. jurisdictions, and revised prior notice requirements for transactions, dividends, and other distributions, with the first annual group capital calculation due in 2026. Bulletin 2026-02
MISCELLANEOUS HEALTH / ACCIDENT
District of Columbia enacted a bill under the Universal Paid Leave Amendment Act to protect workers by ensuring short-term disability insurance benefits cannot be reduced or offset due to benefits received under the DC paid leave program. The legislation prohibits insurers from reducing benefits under any temporary or short-term disability policy, regardless of where the policy was issued, executed, written, or delivered, and clarifies relevant definitions and coordination rules. B 573
PHARMACY BENEFIT MANAGERS
Louisiana released a directive to pharmacy benefit managers (PBMs) and health insurance issuers to clarify reimbursement of professional dispensing fees under Act 474. The directive requires PBMs to use a reimbursement formula combining a NADAC-based drug price, an adjustment factor, and a professional dispensing fee, and sets a minimum fair and reasonable reimbursement of NADAC + $9.00 for a 30-day supply. Directive 257
Maine amended its insurance regulations to align with Public Law 2025, Chapter 291, prohibiting pharmacy benefits managers (PBMs) from engaging in spread pricing in state-regulated health plans, except for MaineCare. The amendments revise the definition of “spread pricing,” remove any references to generating savings from spread pricing, and explicitly bar carriers and PBMs from facilitating or entering contracts involving spread pricing, directly or indirectly. Carriers and PBMs must submit an annual CEO- or CFO-signed certification by December 31 confirming full compliance with the prohibition. Insurance Rule Ch. 210 s 1
Massachusetts implemented new regulations to establish reporting requirements for pharmacy benefit managers (PBMs). The regulation requires PBMs to submit data on wholesale acquisition costs, formulary and maximum allowable cost lists, discounts, utilization limits, rebates, and administrative service fees, enabling the Department to analyze drug pricing, track rebate trends, and assess amounts retained or passed through to health plans. 957 CMR 12.01
PRE-NEED CONTRACTS
North Carolina strengthened its regulations regarding compliance and transparency in preneed trust fund transfers between financial institutions. Preneed licensees must now direct funds to transfer directly and solely from the original to the substitute institution, eliminating intermediary handling, and notify the Board within 10 days using a prescribed form. The form must include detailed information on the licensee, preneed contract, financial institutions, beneficiaries, and signatures attesting to the transfer and receipt of funds,. 21 NCAC 34D .0304
REGULATORY REPORTING REQUIREMENTS
Arkansas issued a bulletin clarifying pharmacy network adequacy data submission requirements for issuers that use pharmacy benefit managers. The bulletin reiterates that issuers must file an annual pharmacy network adequacy report by March 1 each year, covering data from the prior calendar year. It emphasizes that while PBMs may assist, issuers remain fully responsible for timely, complete, and accurate filings. Bulletin 2-2026
Delaware revised its bulletin to require all admitted and approved domestic and foreign insurers to provide direct telephone numbers and e-mail addresses for employees corresponding with the DOI, improving communication efficiency during consumer complaint investigations. The revision extends this requirement to all contact types listed on UCAA Form 14, mandates updates within 30 days of personnel changes (with immediate updates for Catastrophe/Disaster Coordination contacts), and encourages annual reviews of contact information in State-Based Systems. Domestic-Foreign Insurers Bulletin 98 (Revised 2)
Illinois published a bulletin to update filing instructions for annual insurance supplier diversity reports. The bulletin applies to insurers, HMOs, limited health service organizations, dental service plan corporations, and accredited reinsurers with at least $50 million in net admitted assets, detailing how to complete and submit reports through SERFF using the designated TOI/sub TOI for supplier diversity. Illinois requires accurate reporting of procurement categories, inclusion supplier types, and any unusual circumstances, with the first report due April 1, 2026. Bulletin 2026-03
Massachusetts issued guidance for health insurance carriers regarding compliance with state and federal mental health parity laws, including the Mental Health Parity and Addiction Equity Act, for benefits provided in 2025. Carriers must submit filings through SERFF by July 1, 2026, including a CEO- and CMO-signed Certification of Compliance along with comparative analyses of nonquantitative treatment limitations. HC Filing Guidance Notice 2026-A
Missouri released a bulletin reminding insurers of their annual statistical reporting obligations for all lines of insurance, including property, casualty, life, health, and accident, without introducing new requirements. The bulletin provides filing deadlines, statutory references, and submission methods, including online submission via the DOI’s portal and e-mail for certain ZIP code data. Bulletin 26-03
New York issued a liquidity and severe mortality inquiry to all licensed life insurers and accredited life reinsurers to assess stress liquidity exposure and financial flexibility. Insurers must submit responses by May 1, 2026, through DFS’s secure portal, detailing liquidity plans, stress testing, yield-enhancing activities, rating agency findings, reinsurance agreements, illiquid assets, guarantees, and preparedness for severe mortality events. The inquiry requires disclosure of formal liquidity plans, alternative cash-raising methods, portfolio yield impacts, reinsurance and guarantee exposures, and potential large or institutional cash demands. Liquidity and Severe Mortality Inquiry - 2026
REPORTS - DATA CALLS & OTHER REPORTS
Pennsylvania requires insurers to submit Medicare Supplement refund calculation data by May 31, 2026, for standardized and pre-standardized plans using the DOI’s Excel workbook via SERFF. Filings must preserve formulas, report experience separately for standard/select and pre-standardized plans, and include explanations for any discrepancies from prior submissions. 2026 Medicare Supplement Data Call
Puerto Rico’s Insurance Commissioner requires all health service organizations and insurers to submit health data on women of reproductive age, infants, children, and adolescents covered during July 1, 2024–June 30, 2025, using Department of Health forms. Circular Letter CC-2026-2058-AF
RESERVE VALUATION
Oklahoma adopted the NAIC 2025 Valuation Manual amendments for life and accident & health insurers. The Order formalizing adoption is available on the Oklahoma Insurance Department website, and insurers with questions may contact their assigned financial analyst. Notice Dated 2/11/26
TRADE PRACTICES
California amended its Civil Code and the Military and Veterans Code to strengthen protections for service members and veterans against deceptive practices, unreasonable fees, and exploitation related to veterans’ benefits and services. The bill expands the definition of public social services to include a broader range of veterans’ benefits, limits fees for veterans’ benefits to amounts permitted under federal law, and clarifies prohibitions on accessing Common Access Cards or requiring login credentials for federal systems. SB 694
Texas amended its trade practices rules to expand out-of-network provider disclosures, claim dispute resolution, and EMS rate and payment requirements, including applying these rules to higher education health plans. Amendments clarify mediation deadlines, EOB instructions, balance billing protections, and EMS rate submissions, with limits on annual rate adjustments and enforcement through audits and the Texas Open Data Portal. 28 TAC s 21.4902