Extended Transition for Grandmothered Plans

On May 10, 2019, the New Jersey Department of Banking and Insurance published Bulletin 19-05. The purpose of the bulletin is to advise carriers of the department’s intent to continue to permit the renewal of coverage pursuant to the CCIIO’s latest transitional policy extension for non-grandfathered non-ACA-compliant plans (called “grandmothered plans”) in the individual and small group markets. As background, on March 25, 2019, CCIIO provided guidance for a transition policy extension that allows insurers the option to renew grandmothered plans as long as the state allows it. Such transition policies are not required to be in compliance with certain ACA mandates including community rating, coverage of essential health benefits, prohibition on pre-existing condition exclusions, and the annual out-of-pocket maximum limit.

According to the bulletin, NJ-issued policies may continue to be renewed on or before October 1, 2020, provided the policy will terminate by December 31, 2020. Insurers may renew early or issue coverage for periods less than one year if a policy terminates prior to December 31, 2020, and (in the case of a small group) if the employer wants coverage through the end of the calendar year. Employers with grandmothered plans should check with their adviser and carrier to determine if the carrier will continue to offer the plan via the extension.

Bulletin 19-05 »