Beginning April 1, 2015, the Insurance Division will be requiring all filers of supplemental health products to review the following Health Care Recurring Issues checklist and complete the following compliance certification. This requirement is being added to reduce the number of non-compliant filings the Department receives and to enhance speed-to-market.
All accident and health insurance filings containing contracts, certificates, riders, endorsements, amendments, advertising, outlines of coverage, applications or rates, whether for individual or group policies must receive Department approval prior to their use. The Department must receive rate filings at least 60 days prior to their projected use and form filings at least 30 days prior to their projected use.
The list below applies to all accident and health filings across the board. Your filing must include all of the following in order for the analyst to begin their review.
SERFF is used only for rate and form filings. Annual reports or other informational documents that do not require a review or approval by the analyst will be rejected.
The entire SERFF filing must be submitted using Adobe Acrobat. It must be backwards compatible to Adobe 5.0. Filings that include components or attachments other than Adobe Acrobat will be rejected. Please note that if a component is larger than 3MB it will be rejected, this includes scanned documents. If you need assistance in this process you may call the SERFF Help Desk.
The Department can not begin to review a filing, unless and until the filing is received in good order. Good order means that all items and information that the Department requires to be included in filings are included in the submission package. This includes the correct filing fee; a fully and correctly completed Form F-106; appropriate NAIC TOI and SUB-TOI product codes; the Vermont filing/tracking numbers (VFNs) and approval dates for all previously approved rates or forms reference in the filing; a certification by a company officer of compliance with all Vermont insurance statutes and regulations; and an authorization letter in the case of third party filings.
For form filings, good order also means that the following are included in the filing: copies of all of the forms being submitted for review and approval by the Department; a detailed and comprehensive “statement of variability” (SOV) that explains all substantive text filed as variable; a narrative description of the purpose of each form; and – in the case of replacement form filings – redlined copies of the forms that highlight the differences between the new forms being filed and the old forms that are being replaced.
The table of contents in all forms must be bookmarked. The SERFF User Guide, available at http://www.serff.com/, provides information on how to add bookmarks.
Rate and Form filings must contain all items referenced in the transmittal memo. In addition all references to previously approved rate and form filings must include the Vermont Filing/State Tracking Number (VFN), the approval date, and in some cases a copy (PDF, and attached to) of the previously approved filing.
Responses: A response to a Filing Objection Letter must be submitted as a Response Letter on SERFF. The Department will not accept responses submitted as Amendments or Notes to Reviewer.
(1) A response to a filing letter must include:
(a) A cover letter identifying the changes made;
(b) Revised documents with all changes highlighted or underlined;
(c) Revised documents incorporating all changes without highlights.
(2) If a filer does not respond to a Filing Objection letter within ninety (90) days, the filing will be closed and its SERFF status will be changed to “disapproval – final”.
All health insurance rate filings on existing products must also include the following information, in addition to the GENERAL FILING REQUIREMENTS:
In addition to the GENERAL FILING REQUIREMENTS, form filings must include the following:
|Supplemental Health Care filings ~ Compliance Certification Form.pdf||18.41 KB|
|Health Care Recurring Issues2015.pdf||29.79 KB|