Statement from Commissioner Pieciak: DFR staff continue to work remotely and will do so until further notice. The department is still conducting business, however there may be some temporary delays in DFR services. 

Health Filings

Filing Submission Requirements
Notices
Annual Health Reporting Requirements
Rates and Forms Health Contacts


Filing Submission Requirements

Filing submission requirements in this section are provided for your guidance only.  All filers all have the responsibility to read and correctly apply the laws as they pertain to each filing.  

Actuarial Memorandum

A comprehensive actuarial memorandum must accompany all filings that include rates. The following minimum elements must be included in each actuarial memorandum

  1. Incurred premium, incurred losses, and loss ratios for Vermont and nationwide, for the past five (5) years.
  2. The number of policy holders and the number of certificates affected in Vermont and nationwide.
  3. The economic impact on Vermont policyholders and/or certificate holders (i.e. change in premium expressed in dollars and percent).
  4. Definitions of all terms and symbols and a projection of loss ratio for Vermont and nationwide. Rates must be filed 60 days before intended use.

Civil Union

To be in compliance with Vermont's civil union coverage's please refer to  Health Care Administrative Bulletin HCA-110. For underwriting and rating limitations see 8 V.S.A. § 4724 (7)(E).

Compliance Certification- Forms Only

The Supplemental Health Care Filing Compliance Certification Form must be accurately completed, signed, and submitted with all FORM filings or it will be rejected; this is a mandatory health form filing submission requirement.  The Department does NOT accept carrier created compliance certifications. This certification was added to the form filing process reduce the number of non-compliant filings the Department receives and to facilitate speed-to-market. Vermont’s “Recurring Issues: Supplemental Health Insurance” document lists the regulatory issues most frequently encountered in the review of supplemental health insurance form filings. Filers must review the Recurring Issues document and make any corrections necessary to their filing to bring it into regulatory compliance.

Flesch Score Certification

Please provide a Flesch Score Certification signed and dated by an officer of the company. Flesch readability form Documents must have a score of at least 40. Bulletin 107 § 4.

Form F-106

A completed Form F-106 is required with every submission.

Health Advertising Restrictions

Materially misleading or deceptive advertising is prohibited. 8 V.S.A. §§ 4724 & 4084.

Details of prohibited advertising activities are found in Regulation 71-1.  Any advertisement that supports or constructs forms that are not offered in Vermont or are forbidden under Vermont Statutes, regulations, or policy may not be used.

Health Application

Must include an authorization to release medical information if any such data is to be sought.

Per Title 8 V.S.A. 4724 (20) The authorization must add an exclusion similar to the following: NOTE: This authorization EXCLUDES the release of any information about previously administered HIV related testing. Please see Bulletin 138 for more information.

Rate Exhibits

Rate Exhibits must include: Vermont Experience Exhibit without interest, Vermont Experience Exhibit with interest, Nationwide Experience Exhibit without interest, Nationwide Experience Exhibit with interest, Vermont Credibility Factor with calculation, Nationwide Credibility Factor with calculation, All lifetime loss ratios clearly marked on exhibits, and rate increases for the past 5 years.

Redlined Copy

Filing must include a side by side comparison if a filing contains a form replacing a previously approved form. Please provide a redlined copy of the changes to your forms.

Statement of Variability

Filings must include a complete explanation of the range of variable material. Forms marked as entirely variable will not be approved.

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.


Notice to Filiers

Annual Aggragate Attachment Points for all Stop Loss Filings

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.

Submission Requirements

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.

Cost of Outside Consultants

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 Health Reporting Requirements

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.

  • Long Term Care
  •  Medical Supplement

Contacts

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

Christine Menard-O'Neil
Rates and Forms Analyst
Christine.Menard-Oneil@vermont.gov
802-828-5589

Anna Van Fleet
Assistant Director of Rates and Forms Life and Health
Anna.VanFleet@vermont.gov
802-828-4843
 
​​Emily Brown
Director of Rates and Forms
Emily.Brown@vermont.gov
802-828-4871

Contact Information

Department of Financial Regulation
Consumer Services 
89 Main Street, Montpelier, VT 05620 - 3101

802-828-3301
833-DFR-HOTLINE (toll free)
833-337-4685 (toll free)

Public Information
For public records, media inquiries, and press releases visit our Public Information web page

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Employee Information