On Apr. 25, CT INS issued bulletin on rate filing submission guidelines.
CT INS issued Bulletin HC-90-24 re filing requirements for individual/small employer group health insurance policies subject to Patient protection and affordable care act.
Follows CT INS Apr. 2024 bulletin on rate filing submission guidelines, see #209667.
Also follows CT INS Mar. 2024 bulletin on individual/small employer filing, #205278.
Applicability
Applies to filings for non-grandfathered policies sold by carriers in the individual and small group markets subject to Patient Protection and Affordable Care Act, (PPACA).
Includes carriers in CT Health Insurance Exchange, as Access Health CT (AHCT).
Form Filing Requirements
All plans in the individual and small employer group markets both on and off the exchange are required to provide coverage for the essential health benefits.
Complete contracts filed for initial filing of fully PPACA compliant individual and small group policies or certificates issued on/after Jan. 1, 2014 both in and out of AHCT.
Subsequent changes to policies may be filed as endorsements or amendatory riders.
Filing accompanied by cover letter that clearly indicates types of changes being made.
The cover letter must clearly indicate which plans will be offered on the exchange.
Any plans not approved prior to open enrollment subject to continual open enrollment.
All form filings may be filed with variable language for plans offered on/off exchange.
Detailed explanation of variability must be included as part of the filing submission.
Must contain a cross reference to the Health Insurance Oversight System identifier.
Rate Filing Requirements
Filings to be made in accordance with Bulletin HC 81-241 re rate filing submission, Bulletin HC-106 re small group rate filings, and Bulletin HC-88 re association business.
No changes accepted after Jun. 1, 2024, unless specifically requested by CT INS.
If carrier finds error in filing, carrier can submit a communication in SERFF filing describing error and location; a change in assumptions will not be viewed as an error.
Policy form and rate filings not approved until review of both submissions is complete.
Under no circumstances can unapproved rate/plan be offered during open enrollment.
Once rate filings approved, carriers not allowed to add or withdraw plans or products.
Other Filing Requirements
Maximum copayment amounts are eliminated with exception of required maximums.
All plans that use formularies or networks are required to submit responses to annual surveys that can be found on the CT INS website under Forms and Applications tab.
Effectiveness
All form filing submissions on or off exchange must be submitted by Jun. 1, 2024
Rate filings by Jun. 1, 2024, for individual or small group plans offered Jan. 1, 2025.
The requirements are for plan years beginning Jan. 1, 2025
