June 16, 2015
On June 3, 2015, Superintendent of Insurance Franchini issued Bulletin No. 2015-021, which supersedes Bulletin No. 2015-012 (See the May 19, 2015 Compliance Corner). The new bulletin makes a correction to the previously issued bulletin. Both bulletins are in reference to the CMS bulletin issued March 5, 2014 outlining transitional policies and their options. PPACA requires states to change the definition of small group from 2-50 employees to 2-100 employees. The March 5, 2014, CMS guidance indicates that states can elect to either implement the change Jan. 1, 2016 or to renew groups of 51-100 into their existing large group policies through Oct. 1, 2015. Bulletin No. 2015-012 incorrectly advised re-enrollment was permitted until Oct. 1, 2016. Bulletin No. 2015-021 correctly advises that large groups of 51-100 employees will be able to re-enroll into their existing policies through Oct. 1, 2015 and may renew for one year only. As of Nov. 1, 2016, all groups with between 51-100 employees must be included in the small group market. As we shared in May, New Mexico employers with between 51-100 employees should work with their insurer in determining whether re-enrollment is appropriate.
Bulletin No. 2015-021 »