Conditional Extension of Renewal for Non-PPACA-Compliant Plans

On March 10, 2017, the New Hampshire Department of Insurance published Bulletin Docket No.: INS-17-014-AB. The bulletin outlines the Department’s position on renewal of non-PPACA-compliant plans in New Hampshire. As background, on Feb. 23, 2017, CMS issued guidance allowing extension of non-PPACA-compliant plans that have been continued since 2014, subject to state and carrier approval. This bulletin is New Hampshire’s approval for such an extension (but with an exception). According to the bulletin, transitional policies can be renewed until Oct. 1, 2018, but no such policy may extend past Dec. 31, 2018. While the CMS guidance allows policy years that are shorter than 12 months, the bulletin reminds insurers that New Hampshire law does not allow renewal for less than a 12-month period. Therefore, the Department will not fully adopt the extended transition allowed by CMS, but will allow only 12-month renewals that occur on or before Jan. 1, 2018. Policies renewing after Jan. 1, 2018, are required to be PPACA compliant.

Employers with non-PPACA-compliant plans should work with their carrier in determining whether their plan can be extended.

Bulletin Docket No.: INS-17-014-AB »