Insights

Short-Term Duration Medical Plan Filing Requirements


On Sept. 14, 2018, Director of Insurance Ramge issued a Notice addressing short-term, limited duration medical plan filing requirements. The notice identifies Nebraska law related to short-term, limited duration policies. As background, the federal government issued final regulations on short-term, limited duration health plans on Aug. 3, 2018.

This bulletin mentions the federally-required notice that must be issued to consumers upon enrollment in a short-term, limited duration policy. NE requires additional consumer disclosures that identify the length of contract, renewability, pre-existing conditions, free look periods, benefits provided, provider networks, external review, association plans, mandatory and permissive state provisions, annual and lifetime limits, and state mandates. Additionally, the notice indicates that insurers will be required to refile these policies to comply with federal and state law and meet certain marketing requirements.

This notice reminds insurers of the state’s requirements for short-term, limited duration health policies. Employers should be aware that though these plans may be a lower cost option for individuals that just experienced a separation of employment, it doesn’t change an employer’s obligation to make an offer of COBRA (or state continuation), if otherwise required.

Notice »