Life and Health News
October 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
Georgia issued updated guidance following the federal court injunction in City of Columbus v. Kennedy, which blocks implementation of the federal Actuarial Value (AV) policy for Plan Year 2026. As a result, some Qualified Health Plans (QHPs) filed for Georgia Access may now be non-compliant. The DOI is allowing re-filing of only those plans it identifies as affected, with changes limited to restoring AV compliance. Bulletin 25-EX-2
AGENT / PRODUCER LICENSING AND APPOINTMENT
New Mexico now requires all name change requests for licensed producers (individuals and business entities) to be submitted online via NIPR.com, discontinuing acceptance of paper forms. A $50 penalty fee applies if changes are reported more than 30 days after the legal name change, and payment must be sent by check or money order with proper memo information. Notice Dated 9/4/25
ARTIFICIAL INTELLIGENCE
Colorado is delaying the implementation of SB 24-205, from February 1, 2026, to June 30, 2026, which establishes consumer protections against algorithmic discrimination in AI systems. The postponement affects compliance and enforcement timelines, including deceptive trade practice provision. SB 4
CAPTIVES
Alabama extended its temporary moratorium on the licensing or registration of new captive insurers and domestic risk retention groups until June 30, 2026. The extension amends Bulletin 2025-01 and directs affected entities not to submit applications or fees during the moratorium period. Applications submitted before March 1, 2025, remain under review and are not impacted. Bulletin 2025-05
CREDIT INSURANCE
Illinois amended its regulations to align credit insurance refund calculations with Department of Insurance rules, now requiring refunds to be computed according to 50 Ill. Adm. Code 1053.10 instead of the previous “at least as favorable” actuarial method. 38 Ill. Adm. Code 110.170
EXCEPTED BENEFITS
North Carolina confirmed that the federal definition of short-term, limited duration (STLD) insurance in 45 C.F.R. 144.103 remains the standard for the state. No STLD plans may be offered unless they comply with this current federal definition, and existing policies issued under prior rules remain valid. Bulletin 25-B-11
HEALTH INSURANCE - COMPREHENSIVE
Arizona is expanding access to COVID-19 vaccinations following the FDA’s approval of updated vaccine formulations limited to high-risk populations. The order directs state health agencies and the Board of Pharmacy to ensure vaccine availability and coverage, allowing providers to administer vaccines based on scientific evidence and clinical judgment. Executive Order 2025-12
California's Department of Managed Health Care issued guidance on AB 144, requiring full-service commercial and Medi-Cal managed care plans to cover preventive services—including COVID-19, RSV, and influenza immunizations—without cost-sharing or utilization management. Coverage must extend to out-of-network and off-label immunizations aligned with CDPH guidance and remain in effect for the entire plan year. DMHC APL 25-015
Colorado adopted an emergency regulation to require health insurance carriers to cover 2025–2026 COVID-19 vaccines as preventive services without cost-sharing. The rules apply to individual, small group, large group, student, and managed care plans, aligning with ACIP and CDPHE guidance, and encourage third-party administrators of self-funded plans to comply for uniform access. The regulation includes provisions for definitions, enforcement, severability, and incorporation by reference. Emergency Reg. 25-E-04
Connecticut confirms that COVID-19 vaccines remain mandatorily covered under state insurance law as part of required immunization benefits. All individual and group health policies must cover vaccines recommended by leading medical organizations, including ACIP, without cost-sharing. Even if ACIP changes its recommendation, vaccine coverage remains mandatory, though insurers may exclude cost-free provider consultations in that case. Bulletin HC-133
District of Columbia clarified that health carriers in the individual, small, and large group markets must continue covering all ACIP-recommended vaccines, including age-appropriate, FDA-approved COVID-19 vaccines, without cost-sharing or restrictive utilization management. Coverage expectations also extend to any vaccines designated by the DC Department of Health via public notice. These requirements do not apply to Medicare, self-funded plans, or limited scope and excepted benefit plans. Bulletin 25-IB-003-09/17
Hawaii issued a memorandum directing all authorized health insurers to continue covering COVID-19 vaccinations for individuals aged six months and older without cost-sharing or utilization management, including for off-label uses. Insurers are also expected to coordinate with providers and the Department of Health to ensure adequate vaccine supply and equitable access, especially for high-risk populations. Clear communication with members and uninterrupted vaccine access are emphasized, with further guidance possible as the situation evolves. Bulletin 25-EX-2
Illinois' Governor launched the Statewide Vaccine Access Initiative to ensure broad, equitable access to vaccines amid federal disruptions. Led by IDPH, the initiative authorizes expanded vaccine administration, prioritizes underserved populations, mandates insurer coverage without cost-sharing, and enhances outreach through partnerships and accessible guidance. Executive Order 2025-04
Louisiana clarified that health insurers must cover biomarker testing when it demonstrates clinical utility. Insurers cannot impose additional criteria beyond those specified in the law and must use the least restrictive standard when multiple evidence categories apply. The released bulletin emphasizes minimizing care disruptions and ensuring clear, compliant medical policy language. Bulletin 2025-05
Maine released a bulletin requiring health insurance carriers to cover COVID-19 and other immunizations recommended by leading medical academies or authorized by the FDA, without cost-sharing or prior authorization. This includes both the vaccine and its administration, with limited network restrictions permitted. Administrators of self-insured and level-funded plans must notify plan sponsors of these mandates and encourage compliance. Bulletin 486
Massachusetts issued joint guidance from the Division of Insurance and Department of Public Health requiring insured health plans to cover all vaccines and their administration without cost-sharing or utilization management, as long as they follow DPH immunization guidelines. Carriers must update plan documents and online resources to reflect this, and while formulary or network restrictions are allowed, access must still be guaranteed for each recommended vaccine. Self-funded plans are encouraged to follow the same standards. Bulletin 2025-03
Michigan now requires state-regulated health insurance plans, including Medicaid, to cover COVID-19 vaccines and directing agencies like MDHHS, DIFS, and LARA to remove access barriers and promote vaccination. The released directive emphasizes the safety and effectiveness of COVID-19 vaccines and mandates cross-agency coordination to ensure equitable access for all residents. Executive Directive 2025-07
New Jersey issued a bulletin requiring health insurance carriers to continue covering COVID-19 vaccines and their administration without cost-sharing, consistent with state law and public health guidance. Carriers must ensure benefit materials are updated and accessible and encourage non-regulated plans to align with the same standards. Bulletin 25-EX-2
New Mexico requires health insurers and HMOs offering major medical or comprehensive coverage to maintain consistent immunization coverage for the 2025 and 2026 plan years based on the ACIP guidance in effect at the time of rate approval. Changes to immunization coverage reflecting updated ACIP recommendations will only take effect starting with the 2027 plan year. Bulletin 2025-009
Oregon released a bulletin reinforcing that all health benefit plans, including grandfathered ones, must cover FDA-approved COVID-19 vaccines and their administration without cost-sharing or network restrictions. This guidance supports access to vaccines without financial barriers and aligns with the newly formed West Coast Health Alliance’s coordinated immunization efforts. Bulletin 2025-6
Rhode Island mandates that licensed health care entities provide coverage for all COVID-19 vaccines and their administration costs without cost-sharing. This requirement applies to insured plans and encourages administrators of self-funded plans to promote alignment with these provisions, ensuring members face no barriers to accessing COVID-19 vaccinations. Health Bulletin 2025-02
Wisconsin issued a bulletin requiring health insurers and governmental self-funded plans to cover COVID-19 vaccines and their administration without cost-sharing for all eligible policyholders, based on a standing medical order. The bulletin warns that selectively providing cost-free coverage may be considered unfair discrimination unless justified by actuarial or medical evidence. Bulletin Dated 9/16/25
HEALTH INSURANCE / HEALTH RATES
Maine approved average health insurance premium increases for 2026 of 23.9% in the individual market and 17.5% in the small group market, citing rising medical and drug costs and federal policy uncertainty. Notice Dated 9/4/25
Maryland approved 2026 health insurance premium rates with an average increase of 13.4% for individual ACA plans and 4.9% for small group plans, both lower than insurers initially requested. A new state subsidy program will offset the loss of enhanced federal tax credits for low- to middle-income residents. Dental plan premiums will decrease by an average of 1.4%. Notice Dated 9/19/25
HOLDING COMPANIES
Vermont updated its provisions for Insurance Holding Company Systems, including new rules for group capital calculations and electronic filing requirements. The lead state commissioner may exempt certain companies from full filings based on specific criteria and can require filings if financial concerns arise. Regulation 71-2 s 1
MEDICARE SUPPLEMENT INSURANCE
Delaware has amended Title 18, Chapter 34 of the Insurance Code to establish a special open enrollment period for individuals with Medicare supplement policies and to allow transitions from Medicare Advantage plans. Effective annually around a policyholder’s birthday, this new enrollment window permits switching to another Medicare supplement policy with equal or lesser benefits without denial or pricing discrimination based on health status. The bill also allows individuals to move from Medicare Advantage to supplement policies during the federal open enrollment period, subject to individual rating and preexisting condition limits. Insurers must notify eligible individuals 30–60 days before the special enrollment period begins. SB 71
PHARMACY BENEFIT MANAGERS
Colorado updated the annual registration process for pharmacy benefit managers (PBMs). Changes include clarifying that the regulation applies to all PBMs “doing business” in the state, adjusting registration deadlines, and outlining review procedures that allow for suspension or denial with written justification and response rights. PBMs must now renew annually based on their approval date and may have their applications processed by third-party vendors. 3 CCR 702-Reg. 4-2-97
Delaware tightened rules around overpayment recovery and pharmacy audits by insurers, health plans, and PBMs. The bill reduces the timeframe for initiating overpayment recovery from 24 to 12 months and requires concrete evidence of fraud or misconduct to bypass this limit. It also mandates written notice and justification for PBM recoupments and limits extrapolation in audits. HB 212
Massachusetts issued a bulletin outlining new licensure requirements for Pharmacy Benefit Managers (PBMs), effective January 1, 2026. All PBMs must obtain a license from the Division of Insurance by submitting a complete application by October 15, 2025, with a $8,334 filing fee. Bulletin 2025-04
Michigan reminds pharmacy benefit managers (PBMs) of their legal duty to fully cooperate with investigations under the PBM Licensure and Regulation Act and the Third Party Administrator Act. PBMs must provide requested documents and data to DIFS without delay or conditions, and all investigation materials are confidential. Noncompliance may lead to administrative actions, including fines, license suspension, or revocation. Bulletin 2025-20-INS
PREMIUM TAX
Colorado will repeal the reduced insurance premium tax rate for insurers with a home or regional home office in the state beginning January 1, 2026, due to its ineffectiveness in encouraging local workforce growth. The bill raises the tax rate from 1% to 2% and eliminates related statutory provisions by December 31, 2026. HB 1003
REGULATORY REPORTING REQUIREMENTS
Illinois now requires all health insurance issuers to submit and publicly post drug formularies via SERFF by October 1, 2025, including filings for both enrolled individuals and certain health products without enrollees. This requirement applies to new, returning, or expanding issuers and remains effective beyond 2026 unless amended. Bulletin 2025-16
UTILIZATION REVIEW - HEALTH CARE
Arizona issued a bulletin to guide health care insurers on complying with updated prior authorization laws under H.B. 2054. While the requirement for medical director signatures on denial letters has been removed, insurers must still provide written explanations, notify providers within required timeframes, and maintain records identifying the licensed medical professional responsible for each denial. Bulletin 2025-06