Extension of Renewal for Grandmothered Plans

On Feb. 27, 2017, the Maine Bureau of Insurance published Bulletin 420. According to the bulletin, the bureau approves the renewal of non-grandfathered small group plans issued before Jan. 1, 2014 (so-called “grandmothered plans”) for terms extending no later than Dec. 31, 2018. As background, on Feb. 23, 2017, CMS issued guidance allowing extension of grandmothered policies (i.e., non-PPACA-compliant plans that have been continued since 2014), subject to state and carrier approval, and Bulletin 420 is Maine’s approval for such an extension. To be eligible for the extension, carriers must notify the bureau by April 15, 2017, whether or not they intend to renew grandmothered policies beyond Oct. 1, 2017. In addition, grandmothered policies must be terminated or modified to be fully PPACA-compliant by Jan. 1, 2019. For non-calendar-plan years, carriers may renew the policy early on Jan. 1, 2018, or may renew it on its anniversary date in 2018 for a short policy term.

In addition, and importantly for employers with grandmothered policies, carriers must provide 90 days’ notice of transitional renewal or product discontinuance/modification to all grandmothered policyholders. That means any affected employers should receive at least 90 days’ notice with respect to changes to their grandmothered plans. Employers with grandmothered plans should work with their carrier in determining whether their plans will be extended.

Bulletin 420 »