June 12, 2018
On May 30, 2018, the New Jersey Department of Banking and Insurance published Bulletin No. 18-10, which relates to the extension of renewal for non-ACA-compliant plans (also known as “grandmothered plans”). As background, on April 9, 2018, CMS issued guidance allowing extension of grandmothered plans (i.e., non-ACA-compliant plans that have been continued since 2014), subject to state and carrier approval. Bulletin No. 18-10 is New Jersey's approval for such an extension for the full period outlined by the CMS.
Similar to the extension approval for 2018, the bulletin directs carriers to the CMS guidance, meaning New Jersey will accept approvals for extensions based on the CMS bulletin's requirements. The CMS guidance allows an extension of non-ACA-compliant policies to policy years beginning on or before Oct. 1, 2019, provided that all such policies end by Dec. 31, 2019.
New Jersey employers with non-ACA-compliant plans should work with their carriers in extending their policies, as carriers may have their own restrictions (or prohibitions) on extending such plans.
Bulletin No. 18-10 » CMS Guidance »