Health Filing Requirements


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.


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.

General Filing Requirements

Required Supplemental Forms/Documentation:

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.

  • All insurers, submitting filings with the Department for review and approval, must familiarize themselves with the Department’s posted “Most Common Reasons For Delay or Disapproval”; the Department’s “Most Common Reasons For Delay of Disapproval” can be found here (link).
  • Prior to submitting a filing with the Department, an insurer must review their filings for issues identified in the Department’s “Most Common Reasons For Delay or Disapproval”; an insurer’s filing will be denied, and the insurer will have to re-file for review and approval if it appears that no attempt has been made by insurer to address the issues found in the Department’s posted “Most Common Reasons For Delay or Disapproval”.

The table of contents in all forms must be bookmarked. The SERFF User Guide, available at, 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:

  • Rate filings must include the "Company Rate Information" section completely filled out, under the Rate/Rule schedule tab.
  • Earned premium, incurred losses and loss ratios for Vermont and Countrywide for the past five (5) years. Lifetime loss ratio calculations for Medicare Supplement and Long term Care rate filings must be included for Vermont and Countrywide experience. 
  • The number of Vermont policyholders and/or certificate-holders affected and the total number of policyholders and/or certificate-holders nationwide.
  • The economic impact on Vermont policyholders and/or certificate-holders, i.e., change in premium, expressed in both dollar figures and percentages.
  • Rate filings must include an Actuarial Memorandum. The Actuarial Memorandum must be signed and dated, and contain all the information listed in the submission requirements.
  • All health insurance rate filings on new products must follow the same procedure as for rate filings on existing products.  However, if no Vermont experience is available, the carrier must state this in the general information tab.  In cases where Vermont experience is non-existent or not credible, carriers must use the nationwide experience of similar forms with adjustments for differences in Vermont mandated coverage.  Any adjustments must be fully disclosed in the filing general information tab. 
  • Rate filings for SMALL GROUP, NON-GROUP (INDIVIDUAL) COMPREHENSIVE HEALTH INSURANCE and MEDICARE SUPPLEMENT policies are required by Vermont law to be community rated.  Rate filings for these policies must also include the worksheet found as Attachment 1 of the most current Community Rating Regulation (H-99-4).  Small group and non-group carriers must be registered in order to sell to those markets.
  • Rate filings must not be submitted until after the form filing (the product) has been approved.  When submitting a rate filing please reference the form SERFF tracking number and the State tracking number.  Rate filings submitted prior to form filing approval will be rejected.


 In addition to the GENERAL FILING REQUIREMENTS, form filings must include the following:

  • An explanatory paragraph related to each form, describing its intended use; detailing how it will accomplish its goal; identifying the marketing targets; and listing the techniques to be used for each form or group of forms.  The explanatory paragraph must also explain how the new form differs from other previously approved and similar forms. All references to previous filings must include the Vermont Filing/State Tracking Number (VFN), the approval date, the rate change requested, and the rate change approved. 
  • An explanation of the rate impact, if any, of the form filing.
  • Filings that include substantive text filed as variable must include a detailed Statement of Variability (SOV).  All variable material must be bracketed.  In addition a full explanation of the complete range of variables to be used must be included in the SOV.  For more information regarding variability, bracketing and statements of variability, please view the Department’s “Most Common Reasons for Delay or Disapproval” which can be found here (link)
  • Filings that amend, replace, or modify previously approved forms must include the following information:
  • The VFN and approval date of the previously approved forms (and in some instances, copies of the previously approved forms).
  • A redlined copy of the forms with deleted material in strike-through, and new material underlined; and a brief explanation of how the replacement, amended, or modified form differs from the previously approved forms.

Fee Information