Life and Health News
February 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
U.S. Center for Medicare and Medicaid Services issued guidance updating the HHS-developed risk adjustment methodology and DIY software for the 2025 benefit year applicable to ACA-compliant individual and small group health plans. The bulletin outlines technical updates to risk adjustment models, classifications, tables, and software tools, including revisions related to sickle cell disease, recalibration using EDGE data, and ongoing use of the high-cost risk pool. CMS Notice Dated 1/23/26
AGENT / PRODUCER CONTINUING EDUCATION
Illinois updated its regulations to align pre-licensing and continuing education (CE) requirements for insurance producers, limited insurance representatives, and business entities with the NAIC Continuing Education Reciprocity (CER) Agreement. Revisions clarify definitions, require submission of CER Course Filing Forms, outline provider and applicant responsibilities, and set standards for course content and delivery. Updates also revise Exhibits E and H to include indexed life policies and ride-sharing coverage. 50 Ill. Adm. Code 3119.20
AGENT / PRODUCER LICENSING AND APPOINTMENT
Iowa announced updates to licensing and reporting processes for preneed sellers, sales agents, insurers, and financial institutions. Beginning February 13, 2026, preneed seller and sales agent license applications and renewals will be submitted through NIPR LicenseHub, and required annual reports must be filed electronically through OPTins, with sales agents no longer required to submit annual reports. Bulletin 26-01
AGENT / PRODUCER TERMINATION
Maryland released a bulletin outlining how insurers must notify the Insurance Commissioner when a producer’s appointment is terminated for cause. Insurers may submit the required notice and supporting documentation either through the Administration’s online enforcement intake form or by email to the Fraud and Enforcement Division. Bulletin 26-3
CYBERSECURITY
Missouri issued guidance on the Insurance Data Security Act, requiring regulated entities to report cybersecurity events using the Department’s electronic form, including events involving third-party service providers. The bulletin clarifies which entities qualify as licensees and aligns Missouri’s implementation with NAIC Model Law 668. Bulletin 26-01
New York released a warning about a phishing scam targeting DFS-regulated entities, emphasizing that legitimate DFS emails only come from @dfs.ny.gov or @public.govdelivery.com domains. Recipients are advised to verify unexpected requests for payments or sensitive information, avoid links in suspicious emails, and follow cybersecurity best practices. Industry Letter Dated 1/22/26
DISASTER / CATASTROPHIC EVENT
Maryland issued a bulletin in response to a declared State of Emergency requiring health carriers to waive time restrictions on prescription medication refills and to cover pharmacy fills of at least a 30-day supply, regardless of the last fill date. The waiver applies to insurers, nonprofit health service plans, HMOs, dental plan organizations, and the Maryland Health Insurance Plan. Bulletin 26-4
HEALTH INSURANCE - COMPREHENSIVE
Georgia released a bulletin prohibiting step therapy for stage-four metastatic cancer. All health benefit plans, including state employee and Medicaid managed care plans, must cover FDA-approved drugs for this condition without requiring patients to try other drugs first, though plans may verify that use aligns with best practices and peer-reviewed guidance. Bulletin 25-EX-6
Michigan updated the annual co-pay and coinsurance cap for orally administered antineoplastic medications to $254.75 for 2026, reflecting changes in the U.S. prescription drug index. Health insurers must apply this cap to ensure compliance with state law under MCL 500.3406ff(1)(b). Bulletin 2026-02-INS
New Jersey enacted legislation amending multiple insurance and health benefits statutes to require a wide range of health carriers to cover one annual wellness visit per plan year or calendar year for individuals over age three, with no waiting periods permitted. The requirement applies across individual, group, small employer, HMO, and state employee and school employee health benefit plans, and applies to policies or contracts issued or renewed on or after the bill’s operative date. AB 5785
HOLDING COMPANIES
Alabama released a bulletin to advise domiciled insurers subject to the group capital calculation that the Department now follows the filing requirements in NAIC Model Regulation No. 450, including authority to exempt, limit, or require filings for insurance groups. A hearing is scheduled for February 5, 2026, to consider adopting new Section 18.2 of Alabama Insurance Regulation 55, which will codify these filing requirements effective February 15, 2026. Bulletin 2026-01
Arkansas updated its regulations for Insurance Holding Company Systems, modernizing prior notice transaction rules and group capital calculation requirements to align with NAIC standards. The amendments clarify filing procedures, ownership and control of insurer records, termination and indemnification standards, and cooperation obligations during supervision or receivership, while also establishing criteria for exemptions or limited filings for group capital calculations. 23 CAR s 9-118
Florida adopted new requirements under the Insurance Holding Company System Regulatory Act, including group capital calculations and liquidity stress tests. The rule introduces two new NAIC-aligned templates: the Group Capital Calculation 2024 Template and the Liquidity Stress Test 2024 Template. FAC Rule 69O-143.046
MEDICARE SUPPLEMENT INSURANCE
Delaware published a bulletin informing Medicare Supplement carriers and producers of Senate Bill 71, which establishes Guaranteed Issue Special Enrollment Periods (SEPs) for existing policyholders around their birthdays and for individuals transitioning from Medicare Advantage to Original Medicare. Carriers must notify eligible policyholders, honor Guaranteed Issue rights without denying coverage, adhere to existing rating rules, and ensure marketing, underwriting, and training comply with the law. Domestic and Foreign Insurers Bulletin No. 164 & Producer and Adjuster Bulletin No. 40
Nevada issued guidance on Senate Bill 292, requiring insurers offering Medicare supplement policies to provide coverage to individuals under 65 who qualify for Medicare due to disability or end-stage renal disease on the same terms as those 65 or older. Non-compliance may violate SB292 and the state’s Unfair Trade Practices Act, subjecting insurers or producers to investigations, administrative actions, or market conduct examinations. Bulletin 25-006
Vermont clarified that Medicare Supplement policyholders who turn 65 must be automatically moved from disability-rated risk pools to age-based pools, as continuing to charge disabled rates violates community rating and constitutes unfair discrimination. Insurers must reflect compliance in annual rate filings and notify affected policyholders before their 65th birthday. Bulletin 208 (Revised)
MISCELLANEOUS
Illinois now allows insurance companies the option of issuing checks signed by the company name rather than a corporate officer or employee. The revision is intended to enhance security and protect officers and employees from potential risks associated with check issuance. 50 Ill. Adm. Code 904.30
Illinois published a bulletin guiding health insurers on implementing the Uniform Electronic Provider Directory Information Forms (Uniform Directory Template). Issuers must adopt the template by July 1, 2026, verify provider information at least every 90 days, allow providers to update directory data via the template, and ensure no additional information outside the prescribed template is required for NATA-regulated directories. Bulletin 2025-23
Maryland confirmed that the USPS Intelligent Mail Barcode qualifies as a valid “first-class tracking method” under section 1-101 (m-1) of the Insurance Article. This method provides evidence of the date first-class mail is accepted by USPS, supports multiple postal service programs, improves visibility of mail pieces, and may be used whenever a first-class tracking method or certificate of mailing is required. Bulletin 26-2
Puerto Rico amended its Prescription Drug Price Transparency Act to refine retail drug price reporting by pharmacies, focusing on a statistically valid sample of the 100 most frequently prescribed brand-name and generic medications for uninsured patients with retail values over $100. The amendments adjust pharmacy reporting frequency, enhance confidentiality protections, revise the interagency committee’s composition and duties, and require regular public publication of comparative drug price information. HB 1
MISCELLANEOUS HEALTH / ACCIDENT
Arizona issued guidance to ensure compliance with H.B. 2144, requiring insurers to cover biomarker tests that demonstrate clinical utility for diagnosing, treating, managing, or monitoring diseases. The bulletin clarifies that insurers must align policies, guidelines, and manuals with statutory requirements, avoid imposing additional conditions, and provide supporting evidence when denying coverage. Bulletin 2026-01
Oklahoma issued an executive order strengthening oversight of Medicare Advantage plans by imposing new requirements related to provider contracting, payment practices, marketing conduct, solvency, transparency, and network adequacy, with enhanced protections for rural providers. The order requires annual written provider agreements, limits inducements and marketing abuses, and mandates prompt payment and reporting to regulators. Executive Order 2026-01
REGULATORY REPORTING REQUIREMENTS
Maryland released a bulletin requiring all insurers, HMOs, dental plans, nonprofit health service plans, and premium finance companies to update their contact information and disaster-related contacts by April 15, 2026, via the Administration’s online portal. Primary contacts must review and save all information, even if no changes are necessary, and either primary or backup contacts must be available evenings or weekends. Updates must include disaster response plans, continuity of operations plans, pandemic flu plans, and severe event data call contacts. CMS Notice Dated 1/23/26
New Hampshire issued guidance clarifying the format, timing, and method for annual submission of complaint and appeal information by health carriers, managed care plans, and utilization review entities as part of ongoing market-conduct oversight. Beginning with the April 1, 2026 filing, covered entities must submit an annual electronic summary of complaint and appeal data for the prior calendar year using a standardized DOI template, with the initial filing covering calendar years 2024 and 2025. Bulletin INS 26-001-AB
REPORTS - ANNUAL / QUARTERLY STATEMENT
Connecticut issued a bulletin detailing 2026 electronic filing requirements for annual and quarterly financial statements for all authorized insurers, surplus lines insurers, fraternal benefit societies, and health care centers. Filings must follow NAIC instructions and valuation standards, include retention of assets statements, and comply with applicable reinsurance credit regulations, with annual statements due March 1, 2026. Bulletin FS-4-25
Kentucky updated its annual filing instructions to require all insurers to submit specified documents electronically via the eServices portal, effective 2025. Required filings include the Jurat Page, Certificates of Advertising or Deposit, annual and quarterly statements, actuarial certifications, and supplemental policy data. Penalties for late filings range from $100 per day to potential revocation of the Certificate of Authority, and all payments, including renewal fees, must be submitted online. Notice Dated 1/8/26
REPORTS - DATA CALLS & OTHER REPORTS
Arkansas issued a bulletin requiring commercial health insurers offering primary care benefits to submit primary care and medical spending data using the Arkansas Primary Care Payment Improvement Data Collection Template approved by the Primary Care Payment Improvement Working Group. Insurers must submit complete data by February 6, 2026, to allow the Working Group to analyze it and submit recommendations on primary care spending targets to the General Assembly by April 1, 2026. Bulletin 1-2026
Utah updated its instructions and forms for the 2025 Accident & Health Survey, a mandatory annual filing for insurers reporting accident and health business in the state. The survey, including the Stop Loss and ASO supplements, must be submitted electronically by April 1, 2026, and late filings may incur penalties under Utah law. Notice Dated 1/26/26
STANDARD VALUATION LAW
Connecticut published a bulletin certifying that the 2025 updates to the NAIC Valuation Manual meet the requirements of Conn. Gen. Stat. § 38a-78a(b)(1). Insurers writing life, accident, health, and deposit-type contracts must comply with the revised principle-based reserving requirements. Bulletin FS-50
New York updated its valuation regulation to incorporate the 2025 NAIC Valuation Manual by reference for purposes of principle-based reserving. The amendment revises the Superintendent’s authority provisions to replace references to the 2024 Valuation Manual with the 2025 version. 11 NYCRR 103.3
TAX CREDITS
Georgia issued a bulletin specifying documentation requirements for claiming Georgia Housing Tax Credits on annual premium tax returns. Insurers must submit a completed Form IT-HC, partnership K-1 equivalents, and a detailed property schedule with building-level allocations. Bulletin 25-EX-5