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Stop Loss Insurance Data Call

Health Care Stop Loss Insurance Data Call 2025

May 1, 2025

Subject: Request for Vermont Employer Stop Loss Data – All Issuers

To Whom It May Concern:

The Vermont Department of Financial Regulation (DFR) has retained Oliver Wyman Actuarial Consulting, Inc. (Oliver Wyman) to conduct a study regarding potential updates to Regulation H‐2009‐02 (revised). The purpose of this letter is to outline data elements necessary for Oliver Wyman to conduct this study. Our hope is that, to the extent you are willing and able to provide the requested information, it will allow Oliver Wyman to complete an analysis which ultimately leads to decisions that are mutually beneficial for both Vermont employers as well as Vermont insurance carriers.

Below is a description of the information Oliver Wyman would like to receive separately for each group, where applicable, for Vermont employers that had a stop loss coverage issue/renewal date between April 1, 2024, and March 31, 2025:

  • De‐identified group ID (e.g. Group 1, Group 2)
  • Issue/Renewal Date
  • Average number of employees
  • Average number of covered employees
  • Average number of covered lives
  • Number of covered months
  • Aggregate stop loss attachment point as a dollar amount
  • Aggregate stop loss attachment point as a percentage of expected claims (e.g., 120%)
  • Specific/Individual stop loss attachment point for non‐lasered members*
  • Number of lasered covered lives
  • Specific/Individual stop loss attachment point(s) for lasered member (if multiple members and at different attachment points, please list the attachment points)
  • Number of covered lives that have a conditional laser**
  • Specific/Individual stop loss attachment point(s) for member(s) with conditional lasers (if multiple members and at different attachment points, please list the attachment points)

In addition, please provide a response to the following questions:

1. Has the issuer issued policies with specific or aggregate attachment points pursuant to H-2009-02 (revised) § 4 (D): Notwithstanding any provision to the contrary, a stop loss insurer may renew an existing health care stop loss insurance policy using the annual attachment point for claims incurred per individual specified in subsection A(a)(i) and the annual aggregate attachment point specified in subsection A(b)?

Please provide the requested information by June 1, 2025. Respond with data in an Excel file format.

If you have any questions about this request, please email DFR staff at anna.vanfleet@vermont.gov and sebastian.arduengo@vermont.gov


For purposes of this study, lasered members are defined as those for which their specific/individual attachment points are set at a higher level due to their likelihood of incurring high‐cost claims in the upcoming plan year.
** For the purpose of this study, a conditional laser is a higher deductible or coverage limit applied to an individual's claims, but only if a specific diagnosis or treatment protocol is involved.