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A Think Tank of Financial, Capital, Asset, Insurance Regulation

Over 100 Years of Combined Working Knowledge, Experience
Put to Use in Myriad Ways

The esteemed reputation of the Vermont Department of Financial Regulation reflects a long history of quality staff, strong leadership, professional and personal commitment to the mission, and the veritable wealth of knowledge and working experience brought to the table daily by its people. While the majority of the Department work involves that routine for a regulatory authority, at other times, its staff are sought as subject matter experts for various working and ad hoc groups in preparation of special reports, studies, presentations, plans and analyses. You'll find some of those here. Can't find what you're after? Email

Legislative Reports

Reports generated through statute or special Legislature, Committee request. Visit the Vermont General Assembly website for a listing of all Legislative Reports

2024 Legislative Session

January 15, 2024 • Act No. 26 (2023) Report: Workers’ Compensation for Firefighters with Cancer; Eligibility | On January 12, 2024, the Department submitted the legislative report on workers compensation presumptions for firefighters with cancer as required by Act 26 of 2023.

2023 Legislative Session

Act No. 183 (2022) Report: Prior Authorizations; Administrative Cost Reduction | The Department submitted the Act 183 Report to the House Committee on Health Care and the Senate Committees on Finance and Health and Welfare on Feb. 15, 2023.

"Section 36 of Act 183 of 2022, an act relating to economic and workforce development, requires the Department of Financial Regulation (DFR or Department) to explore the feasibility of requiring health insurers and their prior authorization (PA) vendors to access clinical data from the Vermont Health Information Exchange (VHIE) whenever possible to support PA requests in situations in which such a request cannot be automated.

For these reasons, a one-time snapshot of each insurer’s PA requirements would not meaningfully
support the analysis of how to achieve the goal of streamlining the PA process, while imposing a substantial
administrative burden on insurers to submit the data. To better satisfy the goals contemplated
in Act 183, DFR and GMCB propose to strengthen the attestation requirement for insurers that
require prior authorization under 18 V.S.A. § 9418b(h) to better understand and track changes in PA requirements.


Act 137 Report: Insurance Parity in Residential Care for Children and Youth

An advance copy of the Residential Mental Health Report required by Act 137 of 2022. 
February 1 Extension for Report Submission Requested | Section 8 of Act 137 of 2022, an act relating to miscellaneous provisions affecting health insurance regulation, created the Insurance Parity in Residential Care for Children and Youth Working Group to increase access to appropriate residential treatment for children and youth enrolled in commercial health insurance.
Working Group Members

  • Agency of Education
  • Blue Cross Blue Shield of Vermont
  • Brattleboro Retreat
  • Department for Children and Families
  • Department of Financial Regulation
  • Department of Mental Health
  • Department of Vermont Health Access
  • Howard Center
  • MVP Health Care
  • New England School for Girls
  • Office of the Health Care Advocate

Working Group Proposals Focus on Communication and Processes:

Create a process, through which AOE can communicate with DFR, DMH, and local school districts to ensure that students with commercial insurance in residential mental health treatment have the educational resources to which they are entitled under AOE’s supplemental rules.

Amend DFR Rule H-2009-03 to require health insurers to accept DCF licensure as an alternative to external accreditation for residential mental health providers.

Assign case managers to all members of health insurance plans who require residential mental health care.

Create a shared lexicon to minimize misunderstandings caused by differences in terminology between insurers and providers; and

Raise awareness among providers and DMH about services the HCA can provide to patients’ families with respect to coordination of benefits. 


Act 99 Report: Medicare Supplement Open Enrollment Study 

Act 99 (S.239) of 2022 required the Department to convene a group of interested stakeholders to consider several issues related to enrollment in Medicare, Medicare supplement, and Medicare Advantage insurance and marketplaces. The group met four times between the Summer and Fall of 2022. The working group submitted the report to the Legislature on Friday, January 27, 2023.

Working Group Participants  
1. Department of Financial Regulation
2. Department of Vermont Health Access
3. Health Care Advocate
4. Blue Cross Blue Shield of Vermont (BCBSVT)
5. MVP Health Care (MVP)
6. Vermont Association of Hospitals and Health Systems (VAHHS)
7. Community of Vermont Elders (COVE)
8. University of Vermont
9. Vermont Medical Society
10. Dialysis Patient Citizens
11. Amyotrophic Lateral Sclerosis (ALS) Association
12. Area Agencies on Aging

The Department consulted with Oliver Wyman and Risk and Regulatory Consulting (RRC) to provide analysis of issues requiring actuarial and analytical expertise.

The Working Group Recommendations Based Upon Its Findings
Proactive outreach from the State, targeted during open enrollment periods.
Additional training for State Health Insurance Assistance Programs (SHIP) and consumer services staff around what coverage options are available and when.


Pharmacy Benefit Management

Section 5 of Act 131 of 2022, An act relating to pharmacy benefit management, directed the Commissioner of the Department of Financial Regulation (DFR), in consultation with interested stakeholders, to study certain issues related to pharmacy benefit managers (PBMs), which act as an intermediary between health plans and pharmacies, and to deliver a report with findings and recommendations to the House Committee on Health Care and the Senate Committees on Health and Welfare and on Finance on or before January 15, 2023.

2021 and 2022 Legislative Sessions

Federal Mandates

Origins of Essential Health Benefits Benchmark Plans

When the Affordable Care Act was signed into law on March 23, 2010, it triggered comprehensive health insurance reforms to be phased in over four years and beyond. In 2013, on October 1, open enrollment in the Health Insurance Marketplace began. By 2014, all Americans gained access to affordable health insurance options.

The Health Insurance Marketplace®

  • allows individuals and small businesses to compare health plans on a level playing field
  • provides tax credits for middle- and low-income families to cover a significant portion of the cost of coverage


Essential Health Benefits

The ACA mandated that all private health insurance plans offered in the Health Insurance Marketplace® cover ten categories of services — Essential Health Benefits. These include doctors’ services, in-patient and out-patient hospital care, prescription drug coverage, pregnancy and childbirth, mental health services, and more. Some plans cover more services. Plans also must offer dental coverage for children; benefits for adults are optional. Specific services vary by state. The mandate applies specifically to all non-grandfathered health plans in the individual and small group markets.

Vermont Essential Health Benefits Benchmark

Each state must develop state-specific EHB benchmark plans describing services covered under each EHB category. In August 2022, the Vermont Essential Health Benefit Benchmark Plan won approval from the Centers for Medicare & Medicaid Services (CMS) to expand coverage to include prescription hearing aids. Starting in 2024, individual and small group health plans will cover one set of prescription hearing aids every three years and annual exams. It also increases access to nutritional counseling and rehabilitative services. 

The new EHB benchmark plan was approved following a public comment period, review by the Green Mountain Care Board, and collaboration with a diverse array of stakeholders. Coverage for hearing aids is also available for individuals enrolled in Medicaid. Learn more about the Vermont 2014-2022 EHB-benchmark plan on the CMS website.

Vermont EHB Plan Documents   

Commissions, Working and Study Groups

Interagency Health Services Wait Times Statewide Review

Responding to citizen complaints about lengthy wait times for medical appointments, the State of Vermont launched an interagency review of health access throughout the state. The Department worked with healthcare providers, advocates, independent experts, and community members to generate a report detailing its findings and recommendations regarding health service wait times in Vermont. The team presented the Heatlh Services Wait Times Report to the Vermont Legislature in February 2022. 

Health Services Review Team
Agency of Human Services
Jenny Samuelson, Interim Secretary of Human Services
Mike Smith, Secretary Emeritus of Human Services
Ena Backus, Director of Health Care Reform (Investigation Lead)
Wendy Trafton, Deputy Director of Health Care Reform

Green Mountain Care Board
Kevin Mullin, Chairman
Susan Barrett, Executive Director
Professor Jessica Holmes, Board Member
Michele Degree, Health Policy Project Director

Department of Financial Regulation 
Michael Pieciak, Commissioner
Isaac Dayno, Special Assistant to the Commissioner (Project Manager) 
Kevin Gaffney, Deputy Commissioner of Insurance 
Emily Brown, Director of Rates & Forms 
Sebastian Arduengo, Assistant General Counsel 

Report Partners 
Office of the Health Care Advocate 
Oliver Wyman Consulting

Transcripts, media and other related materials

Health Services Wait Times Press Conference

Public Transcripts
   • Wait Time report Public Forum 1 (Oct. 28, 2021)

   • Wait Time report Public Forum 2  (Nov. 4, 2021)


“The Doctor Won’t See You Now: Patients Wait Months for Treatment at Vermont’s Biggest Hospital”, Colin Flanders, Seven Days, September 1, 2021


2017 Merritt Hawkins National Wait Times Survey

Press Releases

  • State Releases Medical Wait Times Report (Feb. 16, 2022)

  • Consumer Resources to Help Locate Available Health Care Provider (Oct. 7, 2021)

  • The Green Mountain Care Board and the Department of Financial Regulation Will Join the Vermont Agency of Human Services to Investigate Wait Times for Medical Appointments (Sept. 3, 2021)

Vermont Educational Health Benefits Commission

Established June 2017 to determine whether and how to establish a single statewide health benefit plan for all teachers, administrators, and other employees of supervisory unions and school districts. The Commission submitted its report to the Legislature on December 18, 2017. 

Commission Members
David Provost, Chair 
Jean Kelty, Executive Assistant 
Michael Pieciak, Commissioner of Financial Regulation 
Diane Lewis, Executive Assistant
Paulette O'Bryan, Executive Assistant
Kaj Samsom, Commissioner of Taxes 
Jeff Fannon, Executive Director of Vermont NEA 
David Van Deusen, Staff Representative 
Nicole Mace, Executive Director, Vermont School Boards Association
Jeff Francis, Executive Director, Vermont Superintendents Association
Barbara Griffin, One non-legislator member appointed by the Speaker
George Cross, One non-legislator member appointed by the Senate Committee on Committees
Data Brokers Working Group

The Department of Financial Regulation and the Attorney General’s Office released a joint Data Broker Working Group Report, as required by Act 66 of 2017. The report recommends that the Legislature consider several potential actions and proposes a legislative definition of the term “data broker.”  

Visit the Attorney General’s website for more related studies and reports.