MT State Updates - 2015 Jan 30 No.01

On June 12, 2015, Commissioner of Securities and Insurance Lindeen issued an Advisory Memorandum regarding the transitional renewal of group health plans for groups with 51-100 employees. As background, on Jan. 1, 2016, under PPACA the definition of small employer changes from 1-50 employees to 1-100 employees. According to the Advisory Memorandum, Montana has adopted a transitional policy for small employers, as allowed by the CCIIO (outlined in a March 5, 2014, CCIIO bulletin, which allows transition relief for non-PPACA-compliant plans with years beginning on or before Oct. 1, 2016).

The Advisory Memorandum provides that a carrier may renew a large group policy for employers with 51 to 100 employees for plan years starting before Oct. 1, 2016. If a carrier chooses this transitional renewal option, it must offer transitional renewal to all of its large employer group policyholders with 51-100 employees. Once the option is made available by the carrier, it will be up to the group policyholder whether to renew as a large group or a small group in 2016.

Employers with 51-100 employees should work with their carriers to see if the transitional renewal is available.

Advisory Memorandum »