Rates & Forms

Insurance Sub-term

Commercial Lines Submission Requirements

Actuarial Memorandum

Include actuarial memorandum for all filings that include a rate component. The actuarial memorandum should be complete and demonstrate all rating changes.

Amendment to a Filing

A filing may be amended at any time prior to the entry on SERFF of a final disposition. Filing amendments must be submitted through SERFF. A new filing is required if a filer wishes to amend a filing after the entry of a final disposition. Regulation I-2010-03 Section 5.(G).

If the only change on a form is its reference number or edition date, it is not necessary to make a filing, pursuant to Regulation I-2010-03 Section 4.(B)(1). The insurer shall maintain an updated list of policy forms that shows the current reference numbers and edition dates of the form and the Vermont SERFF State Tracking Number under which each form was approved.

Broaden, Restrict or Clarify Coverage

If a form or rule replaces or modifies an existing form or rule please provide a description of the intent and effect of the changes. This should include a notation indicating whether the change results in a broadening, restriction or clarification of coverage. Please note that the "Policy Forms and Endorsements" requirement must also be completed.

Commercial Lines Compliance Certification

Sign and attach the Compliance Certification form, certifying the filing is in compliance with Vermont laws, rules, regulations, bulletins and other Vermont filing requirements. *Please note the following: Compliance Certification Form must be submitted simultaneously with the Commercial Lines Property & Casualty Certification Checklist.
Commercial Lines Compliance Certification

Commercial Lines Property & Casualty Checklist

Attach the completed Certification Checklist, verifying the requirements have been satisfied. *Please note the following: Compliance Certification Form must be submitted simultaneously with the Commercial Lines. Commercial Lines Property & Casualty Checklist

Filing Fee

Each rate, rule and form filing (or any combination) must be accompanied by a non- refundable fee of $50.00 or the retaliatory fee whichever is greater. For rating, advisory or service organizations a non-refundable fee of $150.00. Vermont requires the Fee Calculation Explanation on the "Filing Fees" tab to be completed. It must show the following:

  1. The name of each company (if there is more than one).
  2. The state of domicile for each company.
  3. What the state of domicile charges for a filing fee versus Vermont's filing fee.


If the Fee Calculation does not have this information then the filing will be disapproved and an objection letter will be sent. Please also review Vermont’s General Instructions.

Histograms

All rate filings must include histograms showing the percentage and dollar changes in premium, respectively, for all existing policyholders in the filed program.

Loss Cost Adoption Filing

Please include the following forms (attached below), Reference Filing Adoption Form, Summary of Supporting Information Form, and form with variable expense constants.

  1. LC Adoption Form
  2. LCM with ExpCnst
  3. LCM with no ExpCnst

Policy Forms and Endorsements

If this filing includes any forms and/or endorsements that change or amend any previously approved forms, attach the previously approved forms here. Please note that the "Broaden, Restrict & Clarify Coverage" requirement must also be completed.

Rate Filings & Supporting Information

The Uniform experience rating plan shall be the exclusive means of providing prospective premium adjustment. Insurers may file rating plans that provide for retrospective premium adjustments based upon an insured's past experience. Any such submission shall be submitted at least 15 working days before its proposed effective date. Each rate filing shall include actuarial backup or supporting information which shall be comprised of: a written summary of the experience and judgment of the filer and the experience or data of other insurers or organizations relied upon by the filer, the interpretation of any statistical data relied upon by the filer; the description of methods used in making the rates or relied upon in the adoption of the rates and any other such information relied upon by the filer. Company Financial data is required as well as the Vermont Filing Adoption Form and Summary of Supporting Information, shown as exhibits in Bulletin 99.

Readability

The Commissioner shall not approve any form unless the policy or certificate is written in non-technical, readily understandable language, using words of common, every day usage. The policy text shall achieve a minimum score of 40 on the Flesch reading ease test or an equivalent score on any other approved comparable reading test per Regulation I-2010-03

Side-By-Side Comparisons

Each filing submission shall be accompanied by a side-by-side comparison. The exhibit shall compare the new rule(s), rate(s), or form(s) with the rate(s), rule(s), or form(s) being replaced. If a filing includes forms, rules or rates that replace existing forms, rules or rates, side-by-side comparisons should be attached. The side-by-side comparison should be presented in a strikeout and underline format. See Regulation I-2010-03

Third Party Filing Authorization

Any insurer who uses a third party to submit, defend and approve contract provisions, must submit a letter of authorization which names the appointed agent, the date and duration of such authorization and any limits which the company impose on the agent. The authorization must be signed by an officer of the corporation.

Vermont Amendatory Endorsements

Attach Vermont amendatory endorsements for all products that require the endorsements and are used with the policy. If a filer meets this requirement through the adoption of Vermont amendatory endorsements filed by their Advisory Service Organization (e.g. ISO, AAIS), it will be sufficient to attest to this fact.

What's New? - Property and Casualty

NOTICE TO FILERS

Effective immediately and in accordance with the requirements of 8 V.S.A. Section 18, the Rates & Forms Section of the Vermont Department of Financial Regulation will begin billing back to filers the reasonable costs of outside consultants hired to review filings.  While the most significant impact of this policy will be on rate filings requiring prior actuarial review, the statute cited above applies to both rate and form filings.  Therefore, an especially complex form filing that, in the commissioner’s discretion, requires review by outside consultants may also be subject to this policy.

Questions about this policy may be directed to Kevin Gaffney, Director of Rates and Forms, at (802) 828-4845 or Phil Keller, Director of Insurance Regulation, at (802) 828-1464.
 


Bulletin 189 - "Non-Cumulation" Policy Provisions

Bulletin 186 - Price Optimization in Personal Lines Ratemaking

Bulletin 184 - Property Loss Claims: No Labor Depreciation
 

Personal Lines Submission Requirements

Include actuarial memorandum for all filings that include a rate component. The actuarial memorandum should be complete and demonstrate all rating changes.

 

A filing may be amended at any time prior to the entry on SERFF of a final disposition. Filing amendments must be submitted through SERFF. A new filing is required if a filer wishes to amend a filing after the entry of a final disposition. Regulation I-2010-03 Section 5.(G).

If the only change on a form is its reference number or edition date, it is not necessary to make a filing, pursuant to Regulation I-2010-03 Section 4.(B)(1). The insurer shall maintain an updated list of policy forms that shows the current reference numbers and edition dates of the form and the Vermont SERFF State Tracking Number under which each form was approved.

 

If a form or rule replaces or modifies an existing form or rule please provide a description of the intent and effect of the changes. This should include a notation indicating whether the change results in a broadening, restriction or clarification of coverage. Please note that the "Policy Forms and Endorsements" requirement must also be completed.

 

Per Regulation I-2010-03 the filer must certify using the following language that the filing has been properly completed and is in compliance with all applicable Vermont laws, regulations and policies: "I certify that the attached filing has been completed in accordance with Vermont Regulation I-2010-03 and is in compliance with all applicable Vermont laws and regulations." The Certification Statement must be on the General Information Tab.

 

Each rate, rule and form filing (or any combination) must be accompanied by a non- refundable fee of $50.00 or the retaliatory fee whichever is greater. For rating, advisory or service organizations a non-refundable fee of $150.00. Vermont requires the Fee Calculation Explanation on the "Filing Fees" tab to be completed. It must show the following:

1. The name of each company (if there is more than one).

2. The state of domicile for each company.

3. What the state of domicile charges for a filing fee versus Vermont's filing fee.

If the Fee Calculation does not have this information then the filing will be disapproved and an objection letter will be sent. Please also review Vermont’s General Instructions.

 

All rate filings must include histograms showing the percentage and dollar changes in premium, respectively, for all existing policyholders in the filed program.

 

Please include the following forms (attached below), Reference Filing Adoption Form, Summary of Supporting Information Form, and form with variable expense constants.
LC Adoption Form
LCM with ExpCnst
LCM with no ExpCnst

 

If this filing includes any forms and/or endorsements that change or amend any previously approved forms, attach the previously approved forms here. Please note that the "Broaden, Restrict & Clarify Coverage" requirement must also be completed.

 

The Uniform experience rating plan shall be the exclusive means of providing prospective premium adjustment. Insurers may file rating plans that provide for retrospective premium adjustments based upon an insured's past experience. Any such submission shall be submitted at least 15 working days before its proposed effective date. Each rate filing shall include actuarial backup or supporting information which shall be comprised of: a written summary of the experience and judgment of the filer and the experience or data of other insurers or organizations relied upon by the filer, the interpretation of any statistical data relied upon by the filer; the description of methods used in making the rates or relied upon in the adoption of the rates and any other such information relied upon by the filer. Company Financial data is required as well as the Vermont Filing Adoption Form and Summary of Supporting Information, shown as exhibits in Bulletin 99.

 

The Commissioner shall not approve any form unless the policy or certificate is written in non-technical, readily understandable language, using words of common, every day usage. The policy text shall achieve a minimum score of 40 on the Flesch reading ease test or an equivalent score on any other approved comparable reading test per Regulation I-2010-03

 

Each filing submission shall be accompanied by a side-by-side comparison. The exhibit shall compare the new rule(s), rate(s), or form(s) with the rate(s), rule(s), or form(s) being replaced. If a filing includes forms, rules or rates that replace existing forms, rules or rates, side-by-side comparisons should be attached. The side-by-side comparison should be presented in a strikeout and underline format. See Regulation I-2010-03

 

Any insurer who uses a third party to submit, defend and approve contract provisions, must submit a letter of authorization which names the appointed agent, the date and duration of such authorization and any limits which the company impose on the agent. The authorization must be signed by an officer of the corporation.

 

Attach Vermont amendatory endorsements for all products that require the endorsements and are used with the policy. If a filer meets this requirement through the adoption of Vermont amendatory endorsements filed by their Advisory Service Organization (e.g. ISO, AAIS), it will be sufficient to attest to this fact.

 

 

What's New? - Health

NOTICE TO FILERS

Please see the Commisioners Statement regarding required Annual Aggragate Attachment Points for all Stop Loss Filings. For any Filings for Employer Stop Loss insurance, please read the commissioners statement carefully for clarity on required Annual Aggragate Attachment Points in the state of Vermont and use our Health Contacts section for any additional questions.

NOTICE TO FILERS

EFFECTIVE 10/01/2017: Filings must be submitted under the proper TOI and Sub-TOI, have a correctly completed and signed Form F-106, have a correctly completed and signed Supplemental Health Care Compliance Certification for FORM filings, a Flesch Score certification, and the correct filing fees and fee calculation under the "filing fee's tab" or the filing will be rejected. In addition, filers will need to provide responses to the Department’s objections within a 30-day timeframe or the filing will be marked disapproved-final. If a filing is rejected or marked disapprove-final, a new filing must be submitted with the proper filing fees. 

Mental Health Parity and Suicide Exclusions

Vermont’s Mental Health Parity Law requires insurers to provide treatment for mental health conditions and substance abuse to the same degree and manner as standard medical treatment, without imposing barriers to receiving appropriate care. For all health insurance policies excluding coverage for suicide, the Department has found the qualifiers of suicide while “sane” or “insane” in Regulation 80-1 as inconsistent with 8 V.S.A. § 4089b. The delineation between “sane” or “insane”, as it relates to a policyholder’s mental state, creates an inconsistency with the mental health parity requirement in Vermont law and therefore should not be included. Please remove qualifiers such as "sane" or "insane" from any suicide exclusions in your filings.

Notice to Filers

Effective immediately and in accordance with the requirements of  8 V.S.A. § 18, the Department will bill back to filers the reasonable costs of outside consultants hired to review rate and form filings. While the most significant impact of this policy will be on rate filings requiring prior actuarial review, the statute cited above applies to both rate and form filings. Therefore, an especially complex form filing that, in the commissioner’s discretion, requires review by outside consultants may also be subject to this policy. Questions about this policy may be directed to Phil Keller, Director of Insurance Regulation, at (802) 828-1464.

Supplemental Health Care Compliance Certification

The Department requires all filers of supplemental health products to review the Recurring Issues Supplemental Health Insurance and complete the Supplemental Health Care Compliance Certification.  This requirement was added to reduce the number of non-compliant filings the Department receives and to enhance the speed-to-market.  Both documents can be found below.

 

Annual Life Reporting Requirements

Annual Reports of Life Insurance Illustrations are required to be submitted through SERFF.  There is no filing fee require.  Please select the filing type “Annual Report”.  Click the link below to find more information on this annual report.
 
 
 
 
 

Annual Health Reporting Requirements

NOTICE TO FILERS

Effective 08/04/2017, Annual Reports for Long Term Care and Medical Supplemental lines are required to be submitted electronically through SERFF. There is no filing fee required. Please select the filing type “Annual Report”. Click the links below to find more information on these annual reports.

 
 
 

Life and Annuity Contacts

Group Life and Annuities
 
Phil Keller
Insurance Regulation Director
(802)828-1464
 
Individual Life and Credit
 
Barbara Prentice
Rates and Forms Analyst
(802)828-4848
 

Property and Casualty Contacts

Commercial Lines:
Rosemary Raszka
Rate and Form Analyst
(802) 828-1686
 
Pat Murray
Rate and Form Analyst
(802) 828-5795
 
Lisa Johnson
Rate and Form Analyst
(802) 828-3301
 
Personal Lines/Commercial Auto/Workers Compensation
Jessica Sherpa
Rate and Form Analyst
(802) 828-2908
 
Individual Risk/Mid-Term Cancellations
Kevin.Gaffney
Director of Rates and Forms
(802) 828-4845
 

Life and Annuity Contacts

 
Individual Life and Credit
Barbara Prentice
Rate and Form Analyst
(802)828-4848
 
Group Life and Annuities:
Phil Keller
Insurance Regulation Directory
(802)828-1464
 
Questions regarding SERFF, Rate and Form filing fees or scheduling an appointment to view filings please contact:
Shelley Stuart:
Program Technician
(802)828-2471

Health Contacts

​​Emily Brown
Assistant Director Rates of Rates and Forms
Emily.Brown@vermont.gov
(802)828-4871

Jamie Gile
Rates and Forms Analyst
Jamie.Gile@vermont.gov
(802)828-1975

Leah Korce
Director of Rates and Forms Life and Health
Leah.Korce@vermont.gov
(802)828-0184

Anna Van Fleet
Rates and Forms Analyst
Anna.VanFleet@vermont.gov
(802)828-4843

 

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