Insights

Transition Plans Extended


On May 1, 2021, Commissioner Rude issued a notice announcing that transitional policies for individual and small group health insurance plans issued in the state (“grandmothered plans”) may continue until January 1, 2023. Insurers may discontinue these plans at any time, but these plans can only be renewed for up to 12 months and must end by January 1, 2023.

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, if the state allows for such an extension. 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. This notice applies this most recent federal extension to the state and allows issuers 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.

2022 Extension of Transitional Health Insurance Plans »