On April 16, 2018, the New Hampshire Insurance Department issued Bulletin INS-18-018-AB, which provides guidance related to transitional small group policies.
As background, on April 9, 2018, CMS announced that states would have the option to further extend renewal of transitional small group and individual policies for policy years beginning on or before Oct. 1, 2019, provided all policies end by Dec. 31, 2019. The non-grandfathered policies had to be in place prior to 2014. If the policy meets requirements, it’s exempt from certain coverage mandates, including community rating, coverage of clinical trials and essential health benefits. Bulletin INS-18-018-AB represents New Hampshire’s approval for the extension through 2019.
The bulletin explains that insurers in New Hampshire have the option of renewing such policies. However, state law requires that premium rates charged by an insurer be guaranteed for at least 12 months. Because federal law prohibits the extension of a policy period beyond 12 months, a policy in New Hampshire can only be renewed for a period of 12 months.
As was the case in 2017, the New Hampshire Insurance Department didn’t fully adopt the extended transitional policy as contemplated by CMS. Rather, the transition period is only extended to policies that are renewed on or before Jan. 1, 2019. Policies renewing after Jan. 1, 2019 are required to be ACA compliant.
New Hampshire small employers that have non-ACA-compliant plans and are interested in renewing should work with their advisors and insurers.
Bulletin INS-18-018-AB »