Insights

Extension of Transition Policies for Non-ACA Compliant Plans


On February 10, 2021, Gov. Pritzker issued Company Bulletin 2021-01, permitting health insurance carriers to continue transitional health insurance plans that renew for a policy year starting on or before October 1, 2022, as long as the coverage comes into compliance by January 1, 2023. As background, on January 19, 2021, 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. Such transition policies are not required to comply 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.

Transitional relief for these “grandmothered” plans has been extended several times before, and this bulletin applies the most recent federal extension to Illinois and allows insurers to renew policies in the individual market and the small group market according to the extended transitional policy for a policy year starting on or before October 1, 2022. This bulletin reflects the guidance allowing states the option to extend transitional policies for individual and small group health insurance plans that have continually been renewed since 2014.

Carriers must notify the Department of Insurance of their intention to operate under this transition guidance by April 30, 2021.

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

Company Bulletin 2021-01 »