NM State Updates - 2015 Jan 11 No.01

On July 14, 2015, Superintendent of Insurance Franchini issued Bulletin No. 2015-24, which expands upon and supersedes Bulletin No. 2015-021 (see the June 16, 2015 Compliance Corner). These bulletins are in reference to the CMS bulletin issued March 5, 2014 outlining transitional policies and their options. PPACA requires states to change the definition of small group from 2-50 employees to 2-100 employees. The March 5, 2014, CMS guidance indicates that states can elect to either implement the change Jan. 1, 2016, or to renew groups of 51-100 into their existing large group policies. New Mexico has elected to allow issuers of large group policies to permit groups of 51-100 employees to purchase new large group coverage until Dec. 31, 2015, and to allow the renewal of large group coverage between Jan. 1, 2016, and Oct. 1, 2016. The renewal is available to any 51-100-sized employer who has coverage prior to Dec. 31, 2015 and can be accomplished using either the existing insurer or a new issuer.

If an insurer makes offers of renewal under this notice, the offer must be made to all of an insurer’s eligible employer groups. Plan year 2015 new or renewed polices issued under this notice shall not be in effect for more than one year. Furthermore, no plans issued under this transition policy shall extend beyond Oct. 1, 2017. Such plans must comply with PPACA requirements applicable to large group market plans. Early renewals are permissible and plans may renew for periods of less than a year if agreed upon by the insurer and the group. Finally, any such renewals must be made on or before Oct. 1, 2016.

Bulletin No. 2015-024 »