Life and Health News
November 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!
AFFORDABLE CARE ACT
Illinois amended its Administrative Code to transition to a full State-based Exchange for Plan Year 2026, affecting health insurers and consumer assistance personnel such as Navigators, In-Person Counselors, and Certified Application Counselors. The updates clarify certification and renewal requirements, eliminate fingerprinting and Illinois business location mandates, and establish DOI-approved training and continuing education standards. A new section, 4515.110, introduces a state-provided education curriculum covering insurance principles, QHP options, affordability programs, Marketplace and Medicaid policies, and outreach skills. 50 Ill. Adm. Code 4515.10
AGENT / PRODUCER LICENSING AND APPOINTMENT
California adopted new amendments removing the 20-hour pre-licensing coursework requirement for license applicants and authorizing fees for completing the 12-hour ethics course certification. The changes conform updates across related sections to align definitions, licensing processes, and education provisions for agents, service contract providers, and other licensees. AB 943
New Mexico released a bulletin detailing the 2026 Agent Appointment Renewal process, requiring all insurers to complete renewals electronically via NIPR. Billing begins January 5, 2026, with payments due by April 30, 2026, and all agent terminations must be processed by December 26, 2025. 2026 Appointment Renewal Notice
Oklahoma issued its 2025 Appointment Renewal Notification to guide insurers on updating Producer Licensing/Appointment contact information and completing electronic appointment renewals via NIPR. Renewal invoices will be available from November 25 through December 31, 2025, and all payments must be submitted by 4 p.m. CST on December 31 to avoid termination of appointments. Insurers must ensure contact information is current, submit terminations by November 14, and resolve disputes with NIPR by November 12. 2025 Appointment Renewal Notification
CYBERSECURITY
California amended its Civil Code to improve the timeliness of data breach notifications. Businesses must now notify affected individuals and authorities within 30 calendar days of discovering a breach, with allowances for law enforcement delays or system restoration. For breaches affecting over 500 California residents, a sample copy of the notification must be submitted electronically to the Attorney General within 15 days. SB 446
California issued guidance on mandatory reporting of personal information breaches for all insurers, producers, support organizations, and related entities. The notice reinforces compliance with the Insurance Information and Privacy Protection Act (IIPPA), requiring timely reporting of breaches involving unencrypted data. Insurers must provide the DOI with copies of breach notifications sent to the Attorney General, sample consumer notifications (excluding personal data), and report breaches affecting affiliates or service providers. Notice Dated 9/30/25
DENTAL INSURANCE
California enacted new legislation to regulate payment methods to dental providers, effective April 1, 2026. The law requires non-fee-based payments as the default and mandates affirmative consent from providers before using fee-based payment methods, which can be revoked at any time. These provisions apply to health plan contracts and policies issued, amended, or renewed on or after that date. SB 386
DISASTER / CATASTROPHIC EVENT
Arizona published a bulletin in response to severe flooding in Gila County following the Governor’s September 27, 2025, emergency declaration. The bulletin urges insurers to provide at least 90 days of relief to affected policyholders, including grace periods, payment flexibility, and waived fees, to ensure continuity of coverage and claims processing. Bulletin 2025-09
DISCRIMINATION
Colorado published a bulletin for life insurers clarifying the quantitative testing reporting requirement under section 5.A.11 of Regulation 10-1-1. The bulletin waives this reporting for annual reports due December 1, 2025, pending finalization of testing rules, but confirms that all other provisions of the regulation remain enforceable. Insurers are advised to comply with the requirement in future reports once the rules are adopted and may contact the Division for guidance. Revised Bulletin B-10.004
Texas released a bulletin to implement SB 1238, prohibiting insurers, including HMOs, from discriminating against widowed individuals. Effective for policies issued, delivered, or renewed on or after September 1, 2025, insurers must ensure coverage, rates, and options treat widowed individuals equally to married individuals. Bulletin B-0014-25
FRAUD / ANTI-FRAUD
Louisiana issued a directive requiring all authorized insurers and HMOs to file annual and supplemental anti-fraud plan reports electronically. Reports must include detailed data on claims, suspicious claims, fraud investigations, recoveries, and resources allocated, and be submitted by April 1 each year. Directive 228
GROUP INSURANCE
California updated its rules for student health insurance coverage, effective July 1, 2026. The amendment allows students to terminate coverage midyear if they graduate, take a leave of absence, or are no longer enrolled, with termination effective within the same or following calendar month. It also requires institutions to grant waivers for students with minimum essential coverage, prohibits related fees, with penalties up to $5,000 per violation or $10,000 for willful violations. AB 594
HEALTH INSURANCE - COMPREHENSIVE
California is now reducing out-of-pocket costs for insulin and eliminating coverage barriers. Beginning January 1, 2026, large group health plans and policies, and beginning January 1, 2027, individual and small group plans, may not impose cost-sharing over $35 for a 30-day supply of insulin. The bill also prohibits step therapy requirements for insulin and requires large group plans to cover at least one insulin product for each drug type in all forms and concentrations on their formularies. SB 40
California released a bulletin implementing AB 144 to ensure continued access to preventive care, including federally or state-recommended immunizations as of January 1, 2025. Health insurers must cover preventive services with USPSTF “A” or “B” ratings, ACIP recommendations, or HRSA guidelines without cost-sharing, including public health emergency-related immunizations, and implement any CDPH updates within 15 business days. Coverage includes childhood evaluations, immunizations, and laboratory services, and specific vaccines such as COVID-19, influenza, and RSV for eligible populations must be covered starting October 8, 2025, even if used off-label under FDA guidelines. Bulletin 2025-14
MISCELLANEOUS
California announced the launch of Sircon Online “Additional State Service Requests”, expanding electronic submission and fee payment for 10 specific licensing and bond forms. This service builds on the DOI’s 2019 transition to Sircon and aims to streamline filings for insurers, agents, brokers, and education providers. Notice Dated 10/17/25
Colorado issued a bulletin addressing the impact of the federal government shutdown on approximately 57,000 federal employees and their families. The Division urges carriers to prevent coverage lapses by offering a 30-day premium grace period, waiving late fees, providing flexible payment options, and clearly communicating support measures to affected policyholders. Bulletin B-6.05
Connecticut directs all insurers to provide federal employees affected by the government shutdown with at least a 60-day grace period or flexible payment options for premiums. The released bulletin applies to life, health, auto, property, casualty, and other insurance lines and emphasizes maintaining coverage without forgiving premiums or altering policy terms. Bulletin IC-46
Maryland urges insurers and premium finance companies to prevent policy cancellations during the federal government shutdown by deferring payments, extending grace periods, accepting partial payments, and waiving late fees. The published guidance applies to all lines of life, health, property, and casualty insurance and allows insurers to request a permitted accounting practice to admit premium receivables in line with grace periods. The Department emphasizes proactive measures to maintain coverage for residents and businesses facing financial hardship. Bulletin 25-16
Nevada requests insurance carriers assist policyholders impacted by the federal government shutdown by providing premium grace periods, waiving or delaying late fees, and offering flexible payment options to ensure continuous coverage. Bulletin 25-003
Oregon requests insurers and other regulated entities to assist policyholders affected by the federal government shutdown. The released guidance recommends offering at least a 30-day grace period for premiums, flexible payment and fee options, refraining from cancellations or non-renewals, and proactively communicating support measures to affected individuals. Bulletin DFR 2025-8
MISCELLANEOUS HEALTH / ACCIDENT
Arkansas issued a bulletin updating rules for Short-Term, Limited Duration Insurance (STLDI) plans. The bulletin permits authorized issuers to offer STLDI plans with terms under 12 months and renewals up to 36 months, consistent with Arkansas law and recent federal guidance. It reiterates requirements for mandated benefits, disclosure notices, and clear labeling, emphasizing that STLDI plans do not meet ACA standards and advising consumers to consult licensed producers before purchasing coverage. Bulletin 14-2025
Arizona released a bulletin reminding licensed producers to comply with state laws when soliciting and selling health insurance. The bulletin addresses issues such as poor recordkeeping, unauthorized policy sales, and enrolling consumers without consent, urging strict compliance during open enrollment. Violations may result in administrative actions, including license suspension or revocation. Bulletin 2025-07 (INS)
Michigan released updated guidance on short-term limited duration (STLD) insurance and fixed indemnity excepted benefits, reflecting that the federal government no longer enforces certain notice and STLD requirements. Michigan law still limits STLD policies to 185 days per year, exempts them from covering preexisting conditions, and excludes ACA protections, while DIFS continues to review forms and rates. Bulletin 2025-22-INS
OMNIBUS LEGISLATION
California adopted numerous amendments to sections of the Insurance Code. Key updates include clarifying claim reimbursement timelines, expanding blanket insurance eligibility to volunteers, modernizing advertising and licensing provisions with gender-neutral language, and refining qualifications for agents and fraternal benefit society representatives. Additional changes address investment limits for the State Compensation Insurance Fund, service contract administrator definitions, bail licensing, and updates to the Insurance Frauds Prevention Act and securities-related provisions. AB 487
PHARMACY BENEFIT MANAGERS
California enacted reforms to pharmacy benefits and pharmacy benefit managers (PBMs), effective January 1, 2026. The law prohibits plans and insurers from charging enrollees or insureds more than the actual plan-paid cost for prescription drugs and requires transparent cost-sharing. PBMs are assigned fiduciary duties, prohibited from discriminating against nonaffiliated pharmacies, and must use passthrough pricing models with all manufacturer rebates directed to payers to offset costs for plan participants. The law also bans spread pricing, restricts retroactive claim adjustments, ensures nonaffiliated pharmacies can offer delivery, and sets enforcement provisions and penalties for noncompliance. SB 41
New Mexico updated its licensing and reporting requirements for Pharmacy Benefit Managers (PBMs). PBMs must now file new and renewal license applications through the Company Licensing Bureau, pay $500 renewal and $200 annual report fees by March 1, and submit annual compliance reports via SERFF by June 1. Required filings include attestations, audits, contracts, grievance reports, and website information, with confidentiality requests available. Bulletin 2025-011
North Carolina adopted new PBM regulations, enhancing oversight, financial responsibility, and operational standards. The rules cover licensing, fees, financial statements, claim processing, and general administration, including requirements for governing bodies, internal policies, audits, and timely reporting of claim statuses. Initial PBM licenses cost $2,000, annual renewals $1,500, and PBMs must submit audited financial statements and maintain comprehensive management systems to ensure compliance. 11 NCAC 24 .0101
PRE-NEED CONTRACTS
Arkansas adopted amendments to its rules regarding Funeral Expense Insurance, increasing the maximum coverage limit from $15,000 to $25,000. The amendments also update statutory references and revise the Definitions and General Requirements Provisions. 23 CAR s 91-101
REGULATORY REPORTING REQUIREMENTS
Arkansas announced the Draft Version 9.0.2025 of the Data Submission Guide (DSG) for the Arkansas Healthcare Transparency Initiative. The update enhances data clarity for the All-Payer Claims Database by adding denied claims, non-claims payment data, and pharmacy rebate data, while restructuring the guide into three parts for easier use. Bulletin 12-2025
Arkansas issued a bulletin to clarify the definition of “insured employees” under Act 651 of 2025 for group accident and health insurance reporting requirements. The Department interprets the Arkansas Code to require healthcare insurers to provide premium, claim, and enrollment reports if a policyholder employed an average of more than fifty total employees in the prior calendar year, regardless of the number of insured individuals. The bulletin reinforces compliance with this interpretation and provides contact information for related inquiries. Bulletin 13-2025
Maryland released a bulletin updating the Reporting Form for Adverse Decisions and Grievances, effective October 1, 2025, to improve transparency. Carriers must disclose the use of AI in adverse decisions and report zip code-level data identifying the top five areas by adverse/grievance ratios. The updated form must be used for the October-December 2025 report, due January 30, 2026. Bulletin 25-15
Wyoming requires all licensed insurers to submit 2025 premium tax filings and payments through the NAIC OPTins system, effective for filings due March 1, 2026. Paper submissions are no longer accepted, and insurers may consolidate the first three quarterly filings into a single submission to reduce fees. Memorandum 10-2025
STOP LOSS
Arizona issued a bulletin clarifying the regulatory treatment of stop loss insurance products. The bulletin explains that stop loss coverage, typically linked to self-funded employer health plans, is not regulated as group health insurance and must not create a direct relationship between the insurer and individual employees. It further outlines prohibited policy provisions that could transform stop loss coverage into health insurance and emphasizes compliance with Arizona law. Bulletin 2025-08 (INS)
TRADE PRACTICES
Idaho released a bulletin addressing unfair trade practices in marketing Medicare-related insurance products, including Medicare Advantage and Supplement plans. It directs carriers to ensure enrollment applications are accessible, prohibits discouraging sales or altering commissions mid-year, and requires commissions built into rate development to be honored. The bulletin emphasizes carriers’ and producers’ legal and ethical duties to act in consumers’ best interests and warns that violations may result in enforcement. Bulletin 25-06
UNCLAIMED PROPERTY
Arkansas adopted new rules to establish consistent procedures for administering the state’s Unclaimed Property Program. The rules outline requirements for holders, including due diligence, reporting, delivery, and confidentiality obligations, as well as processes for claims, finder agreements, and contract auditors. 18 CAR s 1-101
California amended the Unclaimed Property Law to address digital financial assets, establishing when and how such assets escheat to the state. The law defines key terms and requires holders to transfer unclaimed digital assets, along with any associated keys, to the Controller or a designated custodian within 30 days of reporting. Digital assets unclaimed for three years are subject to escheat, with provisions for notices to owners, handling of partial keys, conversion to fiat currency, and entitlement of claimants to the asset or proceeds, while the Controller may designate custodians for safekeeping. SB 822