Insights

Review of Federal Regulation of Association Health Plans and State Law


On Nov. 21, 2018, Insurance Director Lindley-Myers issued Bulletin 18-04. The bulletin discusses the state and federal regulation of 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 and self-insured group health plans and how Missouri law applies to them.

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

Finally, the Missouri Department of Insurance recommends that any insurer or entity wishing to organize or insure an AHP should submit proposed form and rate filings to the Department. A submitted filing will enable the Department to review the individual facts and circumstances and address any specific organizational questions or concerns that interested parties may have.

Bulletin 18-04 »