Extension of Non-ACA-Compliant Small Group and Individual Policies and Plans

On March 10, 2020, Ohio Superintendent of Insurance Froment released Bulletin 2020-01, extending the ability of health insurance carriers in the individual and small group market to continue transitional health insurance plans that renew for a policy year starting on or before October 1, 2021, as long as the transitional policy ends by December 31, 2021. Previous bulletins have referred to this as a “transitional policy,” but this bulletin is calling the policy a “non-enforcement” policy (this transitional relief has been extended several times).

As background, on January 31, 2020, CMS provided guidance for a transition policy extension that allows insurers the option to renew non-grandfathered non-ACA-compliant plans, as long as the state allows for such an extension. 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. This bulletin applies this most recent federal extension to Ohio and allows the issuer to renew these non-ACA compliant plans.

Small employers that are interested in renewing their non-ACA-compliant plan should work with their advisors and insurers.

Bulletin 2020-01 »