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Proposed Rules and Public Comment

Proposed Rules and Public Comment


Department Update: BCBSVT and BCBSM Proposed Affiliation

Public Comment Period and Public Hearing Have Ended

The public hearing and comment period have concluded. DFR expects to issue orders and findings in the coming weeks. Questions? Write to DFR Assistant General Counsel Hillary Borcherding at Vermont Department of Financial Regulation, 89 Main Street, Montpelier, VT 05620-3101 (USPS mail ) or (email). 


  • Public Comment Period: August 11 - 25, 2023 
  • Public Hearing | Pursuant to 8 V.S.A. §§ 4523(C): August 29, 2023

Link for PDF version of hearing agenda.

Background, Filings and Supporting Documentation

Background on Proposed Affiliation Between Blue Cross and Blue Shield of Vermont and Blue Cross Blue Shield of Michigan Mutual Insurance Company

Blue Cross and Blue Shield of Vermont (BCBSVT) and Blue Cross and Blue Shield of Michigan Mutual Insurance Company (BCBSM) have applied to the Department of Financial Regulation for Department approval of their proposed affiliation. The proposed affiliation is pursuant to the terms of a Principal Transaction Agreement, dated as of April 28, 2023 (the Agreement), by and between BCBSM and BCBSVT. If the proposed transaction is approved and successfully completed, BCBSM will become the sole member of BCBSVT with the right to approve all members of the Board of Directors of BCBSVT. 

Specifically, in connection with the proposed affiliation, the BCBSVT Board will be reconstituted to consist of a total of twelve (12) directors, comprised of: 

  • five (5) individuals appointed by the applicant; and 
  • seven (7) individuals nominated by the BCBSVT Board.

As a result of the proposed affiliation, BCBSM may be deemed to be the ultimate controlling person of BCBSVT and the Vermont Health Plan, LLC.

The proposed affiliation is subject to multiple sections of the Insurance Laws and Regulation of the State of Vermont. These include the following chapters and subchapters of Title 8: Subchapter 13 of Chapter 101 (Holding Companies and Subsidiaries), Chapters 123 (Nonprofit Hospital Service Corporations), 125 (Nonprofit Medical Service Corporations) and Chapter 139 (Health Maintenance Organization).

Filings and Documentation