Insurance Compliance

Washington OIC Guidance on Health Care Benefit Managers

The Washington Office of the Insurance Commissioner (OIC) issued Technical Assistance Advisory 2025-02 to provide guidance on the application of Chapter 48.200 RCW to health care benefit managers (HCBMs), including pharmacy benefit managers. This advisory clarifies requirements related to HCBM registration and oversight, particularly in light of recent legislative changes.

NY DFS Circular Letter: Benefit Offset Provisions for Disability Income Policies

The New York Department of Financial Services issued a circular letter clarifying guidance on benefit offset provisions for disability income policies. The letter reiterates that offsets can only be based on government benefits actually received, not estimated eligibility, with specific allowances for optional, opt-out provisions in group and blanket policies.

Supplemental Spousal Liability Insurance Requirements Update

The New York Department of Financial Services issued Circular Letter 2 (2025) to inform insurers of amendments to Insurance Law § 3420(g) regarding Supplemental Spousal Liability (SSL) insurance. Effective March 26, 2025, the law changes how SSL insurance is offered, requiring it to be automatically included for non-commercial policies only if the applicant indicates they have a spouse, and upon specific written request for other policies.

Property/Casualty Insurers Disaster Planning and Response Guidance

The New York Department of Financial Services issued a circular letter requiring property/casualty insurers to enhance their disaster planning, preparedness, and response capabilities. This guidance outlines expected standards for various insurance entities and replaces previous circulars.

Disaster Planning Guidance for Life and Health Insurers

The New York State Department of Financial Services issued Circular Letter 4, updating guidance on disaster planning, preparedness, and response for life and health insurers. This guidance repeals and replaces previous circulars and outlines expected standards for business impact analysis and operational continuity.

NY Insurers Must Cover Immunizations at No Cost-Sharing

The New York Department of Financial Services issued guidance reminding insurers of their obligation to cover immunizations at no cost-sharing for children and adults. This guidance clarifies existing state law requirements for accident and health insurance policies.

Illinois Bulletin on Inappropriate Claims Denials Based on Location

The Illinois Department of Insurance issued a bulletin clarifying that claims denials based solely on location, site of care, or setting are inappropriate if not grounded in generally accepted standards of care. Insurers must ensure medical necessity determinations are not primarily for economic benefit or convenience.

Illinois Insurance Supplier Diversity Reporting Instructions Update

The Illinois Department of Insurance has issued updated instructions for annual insurance supplier diversity reports, effective for filings on or after April 1, 2026. These updated instructions replace previous guidance and clarify which entities are required to file and how to submit the reports.

Illinois Insurance Bulletin Clarifies PDAA Applicability and PBM Reports

The Illinois Department of Insurance issued Bulletin 2025-20 to clarify the applicability of the Prescription Drug Affordability Act (PDAA) and its reporting and fee requirements for Pharmacy Benefit Managers (PBMs). The bulletin addresses questions raised by PBMs regarding specific coverage types and plan sponsors, and outlines procedures for revised reports and fee adjustments based on recent legislative clarification.

Illinois Insurance Grace Period for Federal Employees During Shutdown

The Illinois Department of Insurance has issued guidance requesting property and casualty insurers to implement protective measures for federal employees impacted by a government shutdown. Insurers are asked to provide a grace period of at least 30 days for premium payments and extensions for repairs to prevent policy cancellations.