Review of Federal Regulation of Association Health Plans and State Law

On Sept. 19, 2018, Insurance Director Rauner issued Bulletin 2018-07. The bulletin discusses the state and federal regulation of association health plans (AHPs), after the DOL’s final rules on AHPs were issued this summer. As background, AHPs are MEWAs and can fall under the jurisdiction of both federal and state law. This bulletin addresses fully insured group health plans and how Illinois law applies to them.

The bulletin essentially confirms that insurers in IL may issue group health insurance to associations that either satisfy the requirements under state law or the DOL’s final rule. Additionally, IL laws regarding the filing and review of group health coverage apply to policies issued to associations that meet the DOL’s requirements.

Finally, the IL Department of Insurance will not require entities to file documents demonstrating an association's qualification for a group health insurance policy, unless the policy incorporates by reference the association's documents.

Bulletin 2018-07 »