OIR-16-04M

INFORMATIONAL MEMORANDUM
                                                   OIR-16-04M
                                                      ISSUED
                                                    June 7, 2016
                                                 Florida Office of Insurance Regulation
                                                    David Altmaier, Commissioner

   TO ALL PROPERTY AND CASUALTY INSURERS AUTHORIZED TO DO
                     BUSINESS IN FLORIDA

                   2015 PROFIT AND CONTINGENCY FACTORS

Pursuant to Rule 69O-170.003, Florida Administrative Code, the Office of Insurance Regulation
annually establishes underwriting profit and contingency factors that may be used in rate filings.
Insurers may use the profit and contingency factors referenced below when they are unable to
produce credible profit and contingency factors from their own data.

      LINE OF BUSINESS                                                           2015 FACTOR
      ALLIED LINES                                                                         3.6%
      BOILER & MACHINERY                                                                   1.9%
      BURGLARY & THEFT                                                                     3.9%
      COMMERCIAL AUTO LIABILITY                                                            0.0%
      COMMERCIAL AUTO PHYSICAL DAMAGE                                                      4.8%
      COMMERCIAL MULTIPLE PERIL (BUSINESS OWNERS)                                          1.2%
      CREDIT                                                                               3.8%
      EARTHQUAKE                                                                           3.5%
      FARMOWNERS                                                                           4.0%
      FIDELITY                                                                             1.9%
      FINANCIAL GUARANTY                                                                   5.0%
      FIRE                                                                                3.6%
      HOMEOWNERS                                                                           4.0%
      INLAND MARINE                                                                        3.6%
      MEDICAL MALPRACTICE - CLAIMS MADE                                                   -3.9%
      MEDICAL MALPRACTICE - OCCURRENCE                                                   -11.0%
      MORTGAGE GUARANTY                                                                    0.2%
      OTHER LIABILITY - CLAIMS MADE                                                       -4.1%
      OTHER LIABILITY - OCCURRENCE                                                        -5.8%
      PRODUCTS LIABILITY - CLAIMS MADE                                                    -4.9%
      PRODUCTS LIABILITY - OCCURRENCE                                                     -9.5%
      SURETY                                                                               3.0%

If you have questions regarding this memorandum, please contact Joe Boor, Actuary, Property
and Casualty Product Review, Florida Office of Insurance Regulation at Joe.Boor@floir.com or
(850) 413-5330.

                                          Page 1 of 1


OIR-16-03M

floir.gov self-hosted-gov; gate-zero FL-a

INFORMATIONAL MEMORANDUM
                                                 OIR-16-03M
                                                   ISSUED
                                                 May 24, 2016
                                              Florida Office of Insurance Regulation
                                                 David Altmaier, Commissioner

   TO ALL WORKERS’ COMPENSATION INSURERS AUTHORIZED TO TRANSACT
                       INSURANCE IN FLORIDA

The purpose of this memorandum is to address the use of unfiled side agreements in conjunction
with workers’ compensation and employer’s liability insurance policies applicable to risks and
exposures in Florida.

The Office of Insurance Regulation (“Office”) has become aware that some insurance companies
are entering into side agreements related to workers’ compensation and employer’s liability
insurance policies. These side agreements sometimes alter the rules, rates, rating plans, forms, or
endorsements that were approved by the Office for use.

The Office would like to remind insurers of pertinent Florida Statutes and Florida Administrative
Code Rules governing workers’ compensation and employer’s liability insurances. Specifically,
Section 627.091(1), Florida Statutes, provides in part: “As to workers’ compensation and
employer’s liability insurances, every insurer shall file with the office every manual of
classifications, rules, and rates, every rating plan, and every modification of any of the foregoing
which it proposes to use.” Section 627.410(1), Florida Statutes, provides:

       A basic insurance policy or annuity contract form, or application form where written
       application is required and is to be made a part of the policy or contract, group
       certificates issued under a master contract delivered in this state, or printed rider or
       endorsement form or form of renewal certificate, may not be delivered or issued for
       delivery in this state unless the form has been filed with the office by or on behalf of the
       insurer that proposes to use such form and has been approved by the office or filed
       pursuant to s. 627.4102.

Rule 69O-189.016, Florida Administrative Code, implements Sections 627.091 and 627.410,
Florida Statutes, and requires in part that each insurer “file with the Office every manual of
classifications, rules, rates, rating plans, deviations and every modification of any of the
foregoing, which it proposes to use.” Rule 69O-189.016(3), Florida Administrative Code, further
requires each insurer to “file with the Office all policy forms and endorsements as defined in
Section 627.402, F.S., which it proposes to use.” The term “policy” is defined in Section
627.402(3), Florida Statutes, to mean “a written contract of insurance or written agreement for or
effecting insurance, or the certificate thereof, by whatever name called, and includes all clauses,
riders, endorsements, and papers that are a part thereof.”

                                            Page 1 of 2
Section 627.191, Florida Statutes, prohibits insurers from making or issuing “a contract or policy
of workers’ compensation or employer’s liability insurance except in accordance with the filings
which are in effect for such insurer, as provided in the applicable provisions of this part, or in
accordance with s. 627.171.” Section 626.9541(1)(h)1.a., Florida Statutes, further prohibits
insurers from knowingly “[p]ermitting, or offering to make, or making, any contract or
agreement as to such contract other than as plainly expressed in the insurance contract issued
thereon.”

If you have any questions regarding the contents of this memorandum, please contact Theresa
Randall, Workers’ Compensation Administrator for the Office of Insurance Regulation, at 850-
413-3821.

                                           Page 2 of 2


OIR-16-02M

INFORMATIONAL MEMORANDUM
                                                                 OIR-16-02M
                                                                   ISSUED
                                                                 April 4, 2016
                                                 Florida Office of Insurance Regulation
                                                  Kevin M. McCarty, Commissioner

              All Private Passenger Motor Vehicle Insurers in the State of Florida

                     Electronic Submission of Report of Rescinded Policies

The Office of Insurance Regulation has implemented an electronic filing system to simplify
reporting rescinded policies. Section 627.728, Florida Statutes, requires private passenger
automobile insurers to complete the underwriting of the policy and make a final determination of
the correct premium for coverage within sixty (60) days after the effectuation of coverage unless
an incorrect premium was charged due to material misrepresentation or fraud on the part of the
insured in the application for insurance. Rule 69O-167.002, Florida Administrative Code,
requires insurers asserting a common law right of rescission or otherwise asserting rights to void
insurance policies ab initio, to report such action to the Office within ninety (90) days of taking
such action.

The Office has developed an Excel spreadsheet as a template for reporting the same information
collected in paper form OIR-B3-493, “Report of Rescinded Policy,” rev. 7/90. Insurers may now
report rescissions of private passenger motor vehicle policies by utilizing the policy rescission
feature found in the Data Collection and Analysis Modules (DCAM) System in the Industry
Portal on the Office’s website.

Each company should have an existing logon account for DCAM, which should be accessed at
https://apps8.fldfs.com/DCAM/logon.aspx. If an account for the Industry Portal does not exist,
follow directions on how to set up an account and create a filing at
http://www.floir.com/siteDocuments/MCRP_DCAM_Account_Instructions.pdf. Detailed filing
instructions for entering rescinded policy data are available within the template and at the
following location: http://www.floir.com/siteDocuments/MCRP_Filing_Instructions.pdf.

This method for reporting rescinded policy information in the DCAM System is available
immediately.

If you have questions regarding the submission of the Report of Rescinded Policies via the
DCAM System, please contact the Market Research and Technology Unit, Florida Office of
Insurance Regulation at MCRP@floir.com or at (850) 413-3147.


OIR-16-01M

INFORMATIONAL MEMORANDUM
                                                                 OIR-16-01M
                                                                   ISSUED
                                                                  3/30/2016
                                                 Florida Office of Insurance Regulation
                                                  Kevin M. McCarty, Commissioner

 TO: All Health Maintenance Organizations (HMOs) and Insurers Authorized to Write Life &
                          Health Insurance Products in Florida

                           Quarterly Comprehensive Health Reporting

This is a notice that the Office of Insurance Regulation (Office) will be initiating a data call on
04/01/2016 for the purpose of Quarterly Comprehensive Health (QCH) data reporting. This data
call is designed to replace the Quarterly Accident & Health Premium and Enrollment Reporting
(commonly referred to as the SMG) which supplied information that was incorporated into the
Managed Care Report. By including indemnity companies along with the HMOs, the Office will
be able to create a full report of the comprehensive major medical and Medicare Advantage
markets in Florida. Also, a new template is included as part of this data call. The template is a
replica of the Annual Statement Analysis of Operations by Line of Business designed to collect
data on a quarterly basis.

The data is to be reported on a quarterly basis with the following deadlines:
       First Quarter is due Monday, May 16, 2016
       Second Quarter is due Monday, August 15, 2016
       Third Quarter is due Tuesday, November 15, 2016
       Fourth Quarter is due Wednesday, March 1, 2017

Each company should have an existing login account for the Industry Portal. If an account does
not exist, visit https://apps8.fldfs.com/DCAM/logon.aspx for directions on how to set up an
account. Detailed instructions for completion of the template can be found at:

              http://www.floir.com/siteDocuments/QCHReportingInstructions.pdf

If you have any questions regarding this request, please contact the Market Research and
Technology Unit at 850-413-3147 or via email at QCHReporting@floir.com.


OIR-16-05M

INFORMATIONAL MEMORANDUM
                                                  OIR-16-05M
                                                   ISSUED
                                                 August 8, 2016
                                               Florida Office of Insurance Regulation
                                                  David Altmaier, Commissioner

    TO ALL LIFE AND HEALTH INSURERS AUTHORIZED TO DO BUSINESS IN
                              FLORIDA

                      Implementation of Principle Based Reserving in Florida

Section 625.1212, Florida Statutes, provides that changes to the valuation of policies and
contracts for life insurance, accident and health insurance and deposit-type contracts will be
effective in Florida the later of January 1, 2017 or the January 1 immediately following the July
1 that Florida’s Insurance Commissioner certifies to the Financial Service Commission that the
statutory conditions prescribed in Section 625.1212(2)(f) have been met. That certification was
made on June 14, 2016; therefore, the operative date of the Valuation Manual in Florida is
January 1, 2017.

Insurers are advised to review the Valuation Manual and plan how best to implement its
requirements. To provide a smooth transition to a principle-based valuation approach, the
Valuation Manual permits a deferral of up to three years. If a company defers principle-based
valuation, it may use the current formulaic approach in the Valuation Manual for policies issued
during the deferral period.

Each Florida domestic Life and Health Insurer subject to 625.1212, Florida Statutes, must notify
the Office by September 1, 2016, whether it will:

   1. Request a Companywide Exemption for 2017 per Section 6.A of Chapter 20 of the
      Valuation Manual (VM-20); or
   2. Use Appendix A and C of the Valuation Manual and if so, provide the anticipated
      mortality basis (i.e. company experience, 2017 CSO, etc.); or
   3. Calculate reserves per the requirement of VM-20.

Notifications should be directed to PBR@floir.com.

If you have any questions regarding the contents of this Memorandum, please contact Eric
Johnson, PhD, ASA, Chief Actuary & Director, Life & Health Product Review, Florida Office of
Insurance Regulation at Eric.Johnson@floir.com or (850) 413-5059.

                                           Page 1 of 1


OIR-17-01M

INFORMATIONAL MEMORANDUM
                                                   OIR-17-01M
                                                     ISSUED
                                                 February 7, 2017
                                                Florida Office of Insurance Regulation
                                                   David Altmaier, Commissioner

    NOTIFICATION TO ALL INSURERS AND HEALTH MAINTENANCE ORGANIZATIONS
                ENGAGING A THIRD PARTY TO PROVIDE SERVICES

The purpose of this informational memorandum is to notify all insurers and health maintenance
organizations (HMO)s, if the insurer or HMO engages a third party to provide services, of certain
provisions of the Insurance Code.

Pursuant to Section 626.8817, Florida Statutes, it is the sole responsibility of the insurer or HMO to
provide for competent administration of its programs. If the insurer or HMO engages the services of an
administrator, the insurer or HMO is responsible for determining benefits, premium increases,
underwriting criteria, and claims payment procedures, and is also responsible for conducting a semi-
annual review of the administrator’s operations when the administrator administers benefits for more than
one hundred (100) certificateholders.

Pursuant to Section 626.883(1), Florida Statutes, an insured’s payment of premiums or charges for
insurance to the administrator shall be deemed to have been received by the insurer. Payments forwarded
by the insurer to the administrator, for purposes of a return of premiums or payment of claims, are not
deemed to have been paid to the insured or claimant until such payments are received by the insured or
claimant.

Pursuant to Section 641.35(3)(a), Florida Statutes, if an HMO, through a health risk contract, transfers to
any entity the obligation to pay providers for subscriber claims, the liability for any such payment remains
with the HMO until the payment is received by the provider and should be reflected in loss reserves.

Pursuant to Section 641.234(4), Florida Statutes, if an HMO, through a health risk contract, transfers to
any entity the obligations to pay a provider for any claims on behalf of a subscriber, the HMO shall remain
responsible for any violations of Sections 641.3155 (prompt payment), 641.3156 (treatment
authorization), and 641.51(4) (balance billing), Florida Statutes.

If you have any questions regarding the contents of this Memorandum, please contact Eric Johnson,
Florida Office of Insurance Regulation at Eric.Johnson@floir.com or (850) 413-5059.

                                                Page 1 of 3
626.8817    Responsibilities of insurance company with respect to administration of coverage insured.—

(1) If an insurer uses the services of an administrator, the insurer is responsible for determining the
benefits, premium rates, underwriting criteria, and claims payment procedures applicable to the
coverage and for securing reinsurance, if any. The rules pertaining to these matters shall be provided, in
writing, by the insurer or its designee to the administrator. The responsibilities of the administrator as to
any of these matters shall be set forth in a written agreement binding upon the administrator and the
insurer.
(2) It is the sole responsibility of the insurer to provide for competent administration of its programs.
(3) If an administrator administers benefits for more than 100 certificateholders on behalf of an
insurer, the insurer shall, at least semiannually, conduct a review of the operations of the administrator.
At least one such review must be an onsite audit of the operations of the administrator. The insurer may
contract with a qualified third party to conduct such review.
(4) For purposes of this section, the term “insurer” means a licensed insurance company, health
maintenance organization, prepaid limited health service organization, or prepaid health clinic.

626.883 Administrator as intermediary; collections held in fiduciary capacity; establishment of
account; disbursement; payments on behalf of insurer.—

(1) If an insurer utilizes the services of an administrator under the terms of a written agreement, the
payment to the administrator of any premiums or charges for insurance by or on behalf of the insured
shall be deemed to have been received by the insurer, and return premiums or claim payments forwarded
by the insurer to the administrator shall not be deemed to have been paid to the insured or claimant until
such payments are received by the insured or claimant. Nothing in this part limits any right of the insurer
against the administrator resulting from the failure of the administrator to make payments to the insurer,
insureds, or claimants.

641.35   Assets, liabilities, and investments.—

(3) LIABILITIES.—In any determination of the financial condition of a health maintenance
organization, liabilities to be charged against its assets shall include:
(a) The amount, estimated consistently with the provisions of this part, necessary to pay all of its
unpaid losses and claims incurred for or on behalf of a subscriber, on or prior to the end of the reporting
period, whether reported or unreported, including contract and premium deficiency reserves. If a health
maintenance organization, through a health care risk contract, transfers to any entity the obligation to
pay any provider for any claim arising from services provided to or for the benefit of any subscriber, the
liabilities of the health maintenance organization under this section shall include the amount of those
losses and claims to the extent that the provider has not received payment. No liability need be
established if the entity has provided to the health maintenance organization a financial instrument
acceptable to the office securing the obligations under the contract or if the health maintenance
organization has in place an escrow or withhold agreement approved by the office which assures full
payment of those claims. Financial instruments may include irrevocable, clean, and evergreen letters of
credit. As used in this paragraph, the term “entity” does not include this state, the United States, or an
agency thereof or an insurer or health maintenance organization authorized in this state.

                                                 Page 2 of 3
641.234   Administrative, provider, and management contracts.—

(4)(a) If a health maintenance organization, through a health care risk contract, transfers to any entity
the obligations to pay any provider for any claims arising from services provided to or for the benefit of
any subscriber of the organization, the health maintenance organization shall remain responsible for any
violations of ss. 641.3155, 641.3156, and 641.51(4). The provisions of ss. 624.418-624.4211 and 641.52
shall apply to any such violations.
(b) As used in this subsection:
1. The term “health care risk contract” means a contract under which an entity receives compensation
in exchange for providing to the health maintenance organization a provider network or other services,
which may include administrative services.
2. The term “entity” means a person licensed as an administrator under s. 626.88 and does not include
any provider or group practice, as defined in s. 456.053, providing services under the scope of the
license of the provider or the members of the group practice. The term does not include a hospital
providing billing, claims, and collection services solely on its own and its physicians’ behalf and
providing services under the scope of its license.

                                               Page 3 of 3


OIR-15-08M

INFORMATIONAL MEMORANDUM
                                          OIR-15-08M
                                            ISSUED
                                        December 15, 2015
                                        Florida Office of Insurance Regulation
                                         Kevin M. McCarty, Commissioner

                        INFORMATIONAL MEMORANDUM

TO ALL VARIABLE ANNUITY WRITERS AUTHORIZED TO DO BUSINESS IN
                          FLORIDA
        MATURITY DATES, EXTENSION AND ANNUITIZATION

The purpose of this memorandum is to clarify some apparent misconceptions regarding
the ability to extend annuity contracts beyond their original maturity date following recent
regulatory settlement agreements (RSAs).

The Office has been made aware of instances where an annuity contract owner has
received communication from an insurer as the maturity date of a contract is approaching
that their only options were to either surrender the contract or annuitize the contract.

Under the provisions of the RSAs, insurers agreed to specific revisions to policies and
procedures regarding the identification and disposal of annuity contracts. Nothing in the
RSAs limits an insurer or annuity contract owner’s options to only surrender the contract
or annuitize the contract at the maturity date. Rather, an explicit requirement of the RSAs
revised business practices allows for the extension of a maturity date upon affirmative
request of the annuity contract owner.

The Office remains committed to ensuring the freedom of choice policy holders have long
had with regard to planning their financial security, and does not believe that any
component of the recent RSAs inhibits continuation of those choices.

Should you have any questions regarding the content of this memorandum, please contact
Anoush Brangaccio, General Counsel at Anoush.Brangaccio@floir.com or at (850) 413-
4116.

                                        Page 1 of 1


OIR-23-04M

INFORMATIONAL MEMORANDUM
                                                   OIR-23-04M
                                                     ISSUED
                                                   July 19, 2023
                                                Florida Office of Insurance Regulation
                                                 Michael Yaworsky, Commissioner

NOTIFICATION TO ALL PHARMACY BENEFIT MANAGERS TO BE REGULATED AS INSURANCE
                              ADMINISTRATORS

                            ~ Implementing Florida’s Prescription Drug Reform Act ~

The purpose of this informational memorandum is to notify all Pharmacy Benefit Managers (PBMs) and
Pharmacy Benefits Plans or Programs of recent changes to Florida Law included within the Prescription Drug
Reform Act (SB 1550). As signed by Governor DeSantis in May, the Prescription Drug Reform Act institutes
new regulatory requirements for all PBMs, including a requirement to become fully regulated as Insurance
Administrators. As the 2023 Florida Statutes have not yet been published, all citations included in this
memorandum and attachments are to the Florida Statutes reflected in Chapter 2023-029, Laws of Florida, a
copy can be found here.

In addition to noticing the formal commencement of rulemaking in the Florida Administrative Register, the
Florida Office of Insurance Regulation (OIR) is providing this informational memorandum to educate
stakeholders on the implementation related activities.

                                   Application for Certificate of Authority

As stated above, the OIR has formally initiated the rulemaking process to promulgate application forms for
PBMs seeking to operate in Florida. Pursuant to the legislation, beginning on January 1, 2024, PBMs operating
in Florida must continue to be registered with the OIR, using the form linked here (s. 624.490, Florida Statutes),
and hold a valid certificate of authority (COA) as an administrator (ss. 626.88 and 626.8805, Florida Statutes).

Given that the new requirements for PBMs exceed both the current registration requirement and the application
requirements of administrators not considered PBMs, all PBMs currently registered with the OIR, including
those that currently hold a COA as an administrator, and any new PBM seeking to operate in Florida, will be
required to complete an application to obtain a COA. The application form is available here. Upon receipt and
review of a complete application by a PBM that meets the requirements of Florida Law, the OIR will issue a
COA.

Any PBM operating in Florida without a valid COA beginning on January 1, 2024, will be subject to a fine of
$10,000 per violation per day. The OIR urges all PBMs to make their application filing as soon as possible to
avoid delays, including obtaining background reports required in the Florida Insurance Code.

                                   Transparent Reporting Requirements

In addition to the referenced application requirements, PBMs will also be subject to a series of transparent
reporting requirements including disclosures related to relationships with affiliated entities and ownership

                                                   Page 1 of 4
affiliations, contracts with affiliates, pharmacies, and pharmacy benefits plans or programs, and several
requirements for specified contractual terms and conditions.

The method in which PBMs and Pharmacy Benefit Plans or Programs shall report the requirements is provided
below:

Financial Condition and Audited Financial Statements: The PBM’s financial condition (subsection
626.89(1), Florida Statutes) and the PBM’s audited annual financial statements (subsection 626.89(2), Florida
Statutes) should be submitted electronically within three months after the end of the administrator’s fiscal year,
through http://www.floir.com/iportal. Form OIR-A3-975 should be used to submit financial information.

Notification of Violations: The notification of any administrative, civil, or criminal complaints, settlements,
or discipline of the pharmacy benefit manager or any of its affiliates which relate to a violation of the insurance
laws, including pharmacy benefit laws in any state should be submitted electronically to
http://www.floir.com/iportal, as a periodic filing, within 30 days of the complaint, settlement, or discipline
(subsection 626.89(5), Florida Statutes).

Network Adequacy Attestation: Beginning January 1, 2024, the requirement for an annual attestation of
compliance with network requirements (subsection 626.89(6), Florida Statutes) should be submitted
electronically to http://www.floir.com/iportal, and included in the annual filings thereafter. PBMs are
encouraged to provide additional documentation (i.e. Network Files, Analyses, etc.) to support this attestation
annually, as it will also be requested during the biennial examination cycle.

Ownership Changes: Material changes of ownership (subsection 626.89(4), Florida Statutes) should
immediately be submitted electronically to http://www.floir.com/iportal, as a periodic filing. A change of
ownership affiliation of any kind with any pharmacy, which meets the requirements of section 626.8814(2)
Florida Statutes, must be reported to the OIR in writing, and may be submitted electronically to
http://www.floir.com/iportal, within 60 days of the change in ownership interest.

Appeals and Denials of Pharmacies and Pharmacists: A report of the total number of appeals and denials
by pharmacies or pharmacists of the PBM’s decisions regarding a drug’s maximum allowable cost and
reimbursement (section 626.8825, Florida Statutes) is required to be filed with the OIR every 90 days. This
report may be filed at the following email address: PBMreporting@floir.com. OIR is creating a suggested
template to use for reporting. Once completed, the suggested template will be posted on OIR's website here.
Use of this template will ensure that the information submitted is complete and the filing can be timely
processed.
Agreements with Pharmacy Benefit Plans or Programs: PBMs are also directed to notify any pharmacy
benefits plans or programs they are contracted with of the requirement (subsection 626.8825(2)(h)2., Florida
Statutes) to annually submit a statement of attestation of compliance with the requirements of subsection
626.8825(2), Florida Statutes, governing contracts between the PBM and the pharmacy benefits plans or
programs. This requirement applies to all pharmacy benefits plans or programs as defined in subsection
626.8825(1)(u), Florida Statutes. The attestations may be submitted to: PBMreporting@floir.com. If the plan
or program is directed by a licensed insurer or HMO, the attestation may be submitted electronically as a
periodic filing to http://www.floir.com/iportal.

                        Contract Provisions to Protect Consumers and Pharmacies

Contracts between a PBM and a Pharmacy Benefit Plan or Program: The bill institutes a series of
protections for both consumers and pharmacies through contracting provisions between PBMs and Pharmacy
                                                   Page 2 of 4
Benefit Plans or Programs. Of note, the bill requires that in addition to any other requirements of the Florida
Insurance Code, all contractual arrangements executed, amended, adjusted, or renewed on or after July 1, 2023,
which are applicable to pharmacy benefits covered on or after January 1, 2024, between a PBM and a Pharmacy
Benefits Plan or Program must include, in substantial form, standard terms, except to the extent not allowed
by law, shall supersede any contractual terms to the contrary. A complete listing of terms can be found in the
bill (s. 626.8825(2), Florida Statutes).

Contracts between a PBM and a Participating Pharmacy: In addition to the above referenced requirements,
the bill institutes a series of protections for both consumers and pharmacies through contracting provisions
between PBMs and Participating Pharmacies. Of note, the bill requires that in addition to any other
requirements of the Florida Insurance Code, a participation contract executed, amended, adjusted, or renewed
on or after July 1, 2023, which are applicable to pharmacy services on or after January 1, 2024, between a
PBM and one or more pharmacies or pharmacists must include, in substantial form, standard terms, except to
the extent not allowed by law, shall supersede any contractual terms to the contrary. A complete listing of
terms can be found in the bill (s. 626.8825(3), Florida Statutes).

Additionally, as published in the Florida Administrative Register, draft rules have been published detailing the
method in which PBMs provide remittance to participating pharmacies.

                                             Patient Data Privacy

The bill also prohibits PBMs from transferring or sharing records relative to prescription information
containing patient-identifiable or prescriber-identifiable data to an affiliated pharmacy for any commercial
purpose other than the limited purposes of facilitating pharmacy reimbursement, formulary compliance, or
utilization review on behalf of the applicable pharmacy benefits plan or program.

                                    Additional Prohibited PBM Practices

In addition to the requirements set forth in the bill, the legislation includes additional prohibitions against PBM
practices including: restricting or penalizing a pharmacy or pharmacist from disclosing relevant information
to a patient, government officials, or law enforcement; communicating at the point-of-sale, or otherwise
requiring, a cost-sharing obligation for a covered person that exceeds the lesser of the applicable amount in
the covered person’s plan or the usual and customary price. Additionally, the bill clarifies that Florida’s
prohibition against “fail twice” step therapy protocols apply to both plans and PBMs.

The bill also provides additional protections against PBMs exerting retaliatory action against pharmacists or
pharmacies that provide information to the OIR pursuant to a compliant or a query regarding compliance with
this act. A complete listing of prohibitions can be found in the bill.

                                        Investigations & Examinations

The bill subjects PBMs to biennial exams beginning on January 1, 2025, to ensure compliance with Florida
law. This requirement is in addition to any investigation or examination conducted because of a referral or
complaint driven investigation or examination conducted at any time.

Any PBM found to exhibit a pattern or practice of knowing and willful violations with section 626.8825
(Pharmacy Benefit Manager Transparency & Accountability), or 626.8827 (Pharmacy Benefit Manager
Prohibited Practices), may be subject to additional penalties per section 626.8828, Florida Statutes.

                                                   Page 3 of 4
Additionally, as published in the Florida Administrative Register, draft rules have been published detailing
the method in which PBMs provide remittance to participating pharmacies and the types of independent
professional examiners who may conduct examinations.

The OIR is also directed to regularly report violations of this act to the Governor, President of the Senate,
and Speaker of the House of Representatives.

This memorandum contains a significant portion of changes in Florida Law but is not intended, nor shall be
considered as, an exhaustive list of all changes in Florida law. The OIR directs PBMs to review the law in its
entirety and to make regulatory changes as necessary to ensure compliance with the law.

For questions regarding this memorandum, please contact InformationalMemoranda@floir.com.

                                                  Page 4 of 4


BULLETIN 26-EX-1: 1332 WAIVER REINSURANCE PROGRAM EXTENSION APPLICATION PUBLIC NOTICE

oci.georgia.gov; gate-zero TOP-20 GA bulletins row. pre-2019 archive sits on a commercial platform; excluded.


BULLETIN 25-EX-4: FOSTERING SUCCESS ACT TAX CREDIT PROGRAM

BULLETIN 25-EX-4

TO:            ALL GEORGIA INSURANCE COMPANIES

FROM:          JOHN F. KING
               INSURANCE AND SAFETY FIRE COMMISSIONER

DATE:          December 31, 2025

RE:          FOSTERING SUCCESS ACT TAX CREDIT PROGRAM
______________________________________________________________________________

The Fostering Success Act, signed into law by Governor Brian Kemp, creates a powerful new
way for your company to make a lasting impact. Insurance companies can now redirect a portion
of their state premium tax liability to help youth aging out of foster care.

Each year, about 600 young Georgians exit the foster care system, often without a stable support
network, leaving them vulnerable to homelessness, unemployment, and poor health outcomes.
This program offers a cost-neutral way for you to contribute to reversing that trend.

Participation is straightforward and provides a 100% dollar-for-dollar premium tax credit.

 ● Preapproval: Insurance companies can seek preapproval from the Department of Revenue.
   For more information visit: https://dor.georgia.gov/qualified-foster-child-donation-credit.
 ● Contribute: Make a donation directly to a qualified foster child support organization.
 ● Receive Credit: The full donation amount is applied as a direct credit against your
   company's state premium tax liability.
 ● Create Impact: Your investment funds will support proven, high-impact programs that
   provide access to higher education, safe housing, counseling, and financial literacy training
   for these deserving young adults.
Redirecting your tax liability is a direct investment in Georgia's future workforce and community
leaders. This initiative empowers youth to achieve self-sufficiency, build healthier lives, and gain
economic mobility. The introduction of these evidence-based programs leads to significant
positive changes. By participating, your company helps reduce dependency on public systems
and directly fuels a homegrown talent pipeline of resilient and motivated individuals for our
state's industries.

I strongly encourage all insurance companies to consider this transformative initiative. By
redirecting your tax liability, you can rewrite the story for these young adults from one of
instability into one of hope and opportunity.
To learn more or begin the process, please contact the Georgia Premium Tax Division at
PremiumTax@oci.ga.gov.

Thank you for your commitment to our communities. Together, we can ensure every young adult
leaving foster care has the chance to succeed.

                                    _____________________________________________
                                    JOHN F. KING
                                    INSURANCE AND SAFETY FIRE COMMISSIONER
                                    STATE OF GEORGIA


BULLETIN 25-EX-5: DOCUMENTATION REQUIREMENTS FOR CLAIMING GEORGIA HOUSING TAX CREDITS WITH ANNUAL PREMIUM TAX RETURNS

BULLETIN 25-EX-5

TO:            ALL INSURERS SUBJECT TO O.C.G.A. §§ 33-5-17, 33-8-4, & 33-40-5

FROM:          OCI PREMIUM TAX DIVISION

DATE:          DECEMBER 31, 2025

RE:            DOCUMENTATION REQUIREMENTS FOR CLAIMING GEORGIA
               HOUSING TAX CREDITS WITH ANNUAL PREMIUM TAX RETURNS

The Georgia Housing Tax Credit, as set forth in O.C.G.A. § 33-1-18, is available to certain
entities subject to insurance premium tax in Georgia.

This Directive provides notice that complete documentation is required to be submitted with the
Annual Premium Tax return in order to obtain credit. Due to recent system changes, OCI is
auditing current-year returns. If documentation is not available at the time of filing, an amended
return should be filed when documentation is available and complete. ESTIMATES WILL NOT
BE ACCEPTED.

Complete documentation includes:

(1)     A properly executed Form IT-HC, with page 3 reflecting the TOTAL amount of credit
        claimed;

(2)     A Georgia K-1 equivalent for each partnership indicating the amount of State credit
        allocated; and

(3)     A schedule that includes each property for which a credit is claimed with a building-by-
        building allocation.

Please contact the Georgia Premium Tax Division at 404-656-7553 or email
premiumtax@oci.ga.gov with any questions.

                                      JOHN F. KING
                                      INSURANCE AND SAFETY FIRE COMMISSIONER
                                      STATE OF GEORGIA


BULLETIN 25-EX-6: STEP THERAPY PROHIBITED FOR STAGE-FOUR METASTATIC CANCER

BULLETIN 25-EX-6

TO:                   ALL HEALTH PLANS IN THE STATE OF GEORGIA

FROM:                 JOHN F. KING
                      INSURANCE AND SAFETY FIRE COMMISSIONER

DATE:                 DECEMBER 31, 2025

RE:                   STEP THERAPY PROHIBITED FOR STAGE-FOUR METASTATIC CANCER

This Bulletin is intended for all health benefit plans1 issued for delivery in Georgia, including any
plans established under Article 1 of Chapter 18 of Title 45 (Georgia state employee plans) and
plans under Article 7 of Chapter 4 of Title 49 (Georgia Medicaid managed care plans).

O.C.G.A § 33-24-59.20 prohibits any health benefit plan from utilizing step therapy (also known
as a “fail first” protocol) for the treatment of stage four advanced, metastatic cancer.2

While plans may ensure that the use of a drug is consistent with best practices for the treatment of
stage four advanced, metastatic cancer and is supported by peer reviewed medical literature, a
health benefit plan which directly or indirectly covers the treatment of stage four advanced,
metastatic cancer may not limit or exclude coverage for an FDA approved drug and may not require
that a patient fails to successfully respond to a different drug or prove a history of failure of such
drug or drugs prior to authorizing treatment or covering such drug.
A health benefit plan shall not require a patient with stage four, advanced metastatic cancer to try
another prescription drug or demonstrate past failure with another prescription drug either
explicitly through the terms of its coverage criteria or indirectly through the use of prior
authorization before having coverage approved for a prescription drug approved for this condition
or where use of the drug for the condition is supported by best practices and peer reviewed medical
literature.

1
  “Health benefit plan” means any hospital, health, or medical expense insurance policy, hospital or medical service contract, employee welfare
benefit plan, contract or agreement with a health maintenance organization, subscriber contract or agreement, preferred provider organization,
accident and sickness insurance benefit plan, or other insurance contract under any other name. The term shall include any health insurance plan
established under Article 1 of Chapter 18 of Title 45 and under Article 7 of Chapter 4 of Title 49, the “Georgia Medical Assistance Act of 1977.”
O.C.G.A. § 33-24-59.20(a)(1).
2
  “Stage four advanced, metastatic cancer” means cancer that has spread from the primary or original site of the cancer to nearby tissues, lymph
nodes, or other areas or parts of the body. O.C.G.A. § 33-24-59.20(a)(2).
This Bulletin is intended to remind health plans of their obligation to comply with O.C.G.A. § 33-
24-59.20 and the Department of Insurance will take regulatory action as necessary to enforce
compliance with such obligation.

                                     _____________________________________________
                                     JOHN F. KING
                                     INSURANCE AND SAFETY FIRE COMMISSIONER
                                     STATE OF GEORGIA


BULLETIN 25-EX-7: MANDATED COVERAGE OF BIOMARKER TESTING

BULLETIN 25-EX-7

TO:                    ALL HEALTH PLANS IN THE STATE OF GEORGIA

FROM:                  JOHN F. KING
                       INSURANCE AND SAFETY FIRE COMMISSIONER

DATE:                  DECEMBER 31, 2025

RE:                    MANDATED COVERAGE OF BIOMARKER TESTING

This Bulletin is intended for all health benefit policies 1 issued for delivery in Georgia, including
any plans established under Article 1 of Chapter 18 of Title 45 (Georgia state employee plans).
O.C.G.A. § 33-24-59.33 requires that all health benefit policies include coverage for biomarker
testing for the purposes of diagnosis, treatment, appropriate management, or ongoing monitoring
of an enrollee’s disease or condition when the testing is supported by any of the following five
criteria:
     (1) FDA Approval: A labeled indication for a test that has been approved or cleared by the
         United States Food and Drug Administration (FDA).

     (2) Indicated Test: A test indicated for an FDA-approved drug or included in the
         warnings/precautions of an FDA-approved drug label.

     (3) CMS Determinations: A national coverage determination made by the federal Centers
         for Medicare and Medicaid Services or a local coverage determination made by a
         medicare administrative contractor.

     (4) Clinical Practice Guidelines: Nationally recognized clinical practice guidelines and
         consensus statements.

     (5) Warnings and precautions on FDA approved drugs.

Further all health benefit policies shall ensure biomarker testing coverage is provided in a
manner that limits disruptions in care, including the need for multiple biopsies or biospecimen
samples. The process for requesting an exception to a coverage policy or appealing an adverse

1
  “Health benefit policy” means any individual or group plan, policy, or contract for healthcare services issued, delivered, issued for delivery, or
renewed in this state which provides major medical benefits, including those contracts executed by the State of Georgia on behalf of state
employees under Article 1 of Chapter 18 of Title 45, by a health care corporation, health maintenance organization, preferred provider
organization, accident and sickness insurer, fraternal benefit society, hospital service corporation, medical service corporation, or other insurer or
similar entity. O.C.G.A. § 33-24-59.33(a)(4).
determination must be readily accessible on the plan’s website. Further, plans are expected to
adhere to the expedited timelines required for urgent medical necessity.

Required Coverage: Examples and Medicare LCDs

To assist in compliance, the Commissioner has identified the following non-exhaustive list of
tests and categories that have met the threshold for coverage based on the criteria above,
specifically referencing Palmetto GBA (MolDX) determinations for the Georgia jurisdiction:

Test Category                   Relevant Evidence / LCD         Application

Comprehensive Genomic           NCD 90.2 / NCCN                 Advanced/Metastatic solid
Profiling (CGP)                 Guidelines                      tumors (Stage III/IV).

Liquid Biopsy                   LCD L37870 (InVisionFirst)      Lung cancer patients
                                                                (NSCLC) where tissue is
                                                                insufficient.

Pharmacogenomics                FDA Labeled Indications         DPYD/TPMT for chemo
                                                                toxicity; CYP2C19 for
                                                                Clopidogrel.

Minimal Residual Disease        LCD L38290                      Monitoring recurrence in
(MRD)                           (Signatera/Guardant)            colorectal and other cancers.

Hereditary Cancer Testing       NCCN Guidelines / LCD           BRCA1/2, Lynch Syndrome,
                                L38966                          and high-risk panel testing.

Neurological/Oncology           LCD L35974                      MGMT Promoter
                                                                Methylation for
                                                                Glioblastoma.

This Bulletin is intended to remind health plans of their obligation to comply with O.C.G.A. §
33-24-59.33 and the Department of Insurance will take regulatory action as necessary to enforce
compliance with such obligation.

                                     _____________________________________________
                                     JOHN F. KING
                                     INSURANCE AND SAFETY FIRE COMMISSIONER
                                     STATE OF GEORGIA


BULLETIN 25-EX-3: IMPLEMENTATION OF NEW COMPLIANCE REVIEW PROGRAM

BULLETIN 25-EX-3

TO:            ALL SURPLUS LINES AGENTS WRITING IN THE STATE OF GEORGIA

FROM:          JOHN F. KING
               INSURANCE AND SAFETY FIRE COMMISSIONER

DATE:          OCTOBER 2, 2025

RE:            IMPLEMENTATION OF NEW COMPLIANCE REVIEW PROGRAM

Beginning in October 2025, the Florida Surplus Lines Service Office (FSLSO) SLIP+ team will
begin conducting compliance reviews of Georgia-licensed surplus lines brokers on behalf of the
Georgia Department of Insurance, Office of Insurance and Safety Fire Commissioner (GA OCI).

The purpose of this program is to ensure brokers are meeting statutory requirements for policy
filing and tax remittance, while also providing educational assistance to strengthen compliance
practices across the Georgia surplus lines market.

Compliance reviews will verify that:

   •    All policies, endorsements, and cancellations are properly filed.
   •    Premium taxes are accurately calculated, reported, and paid.
   •    Broker records align with Georgia surplus lines laws and regulations.
Reviews may be conducted on-site at the broker’s office or as a remote (desk) audit, depending on
circumstances and mutual agreement. Brokers selected for review will receive advance notice and
detailed instructions to prepare the required records.

Compliance reviews may be scheduled on a routine basis, at random, or as a result of identified
reporting discrepancies. In many cases, reviews result in either no findings or minor corrections.
However, significant non-compliance may be referred to GA OCI for further action.

Additional details regarding the process, requirements, and expectations of the Compliance
Review Program are provided in Attachment A.
For questions, please contact compliancereview@slipplus.com or premiumtax@oci.ga.gov.

                                  __________________________________
                                  JOHN F. KING
                                  INSURANCE AND SAFETY FIRE COMMISSIONER
                                  STATE OF GEORGIA

                                                                                2
Attachment A: Compliance Review Program – Additional Details

Purpose and Educational Role
Compliance reviews are designed not only to verify accuracy and compliance but also to serve as
an educational tool. They provide brokers and their staff with feedback, clarification, and resources
to ensure filings are completed efficiently and in alignment with Georgia law.

PROCESS

Notice of Intent & Scheduling
A Notice of Intent will be sent to the broker via email as advance notification of an upcoming
review. Within 5–7 days, a SLIP+ analyst will contact the broker to schedule the review date.
Reviews may take place on-site at the broker’s office or remotely. If multiple licensed brokers
work in the same office, GA OCI may coordinate reviews simultaneously to reduce business
interruptions.

Preparation & Checklist
Once a review date is established, the assigned analyst will provide a detailed list of policies and
transactions selected for review and a Compliance Review Preparation Checklist to assist the
broker             with             preparation             for            the               review.

Records Requested

Records may include, but are not limited to:

   •   Policy records from the past three (3) years, including:
           o Policy declarations (with coverage details and insured property locations).
           o Policy face or front page (if surplus lines stamp is not displayed on the declarations
               page).
           o Endorsements included on the sampling list.
           o Agency invoices issued to policyholders for sampled policies.
           o Proof of premium paid date.
           o Proof of inspections, surveys, or membership agreements related to agency fees.

On-Site Requirements

If the review is conducted at the broker’s office, brokers must provide:

   •   A desk/table and chair.
   •   A telephone and power outlet.
   •   Courtesy space for the analyst to perform their duties.

                                                                                3
Timeline & Findings Report
Brokers will receive a written report of findings within 14 days of the date the review is completed.
Brokers are expected to respond to any variances noted. Findings serve both as corrective direction
and as an educational resource for brokers and agency staff.

Frequency of Reviews

Compliance reviews will take place on a routine cycle, every three (3) years, as part of the normal
oversight process, at random to ensure broad participation across the market, or when reporting
discrepancies or other red flags are identified.

Summary
By preparing ahead of the October program launch, brokers can ensure their reporting and records
are accurate, complete, and in full alignment with state law. Compliance reviews are intended to
support brokers, reduce errors, and strengthen the integrity of Georgia’s surplus lines market.

                                                                                4


BULLETIN 25-EX-2: CITY OF COLUMBUS V. KENNEDY AND RE-FILING OF 2026 RATES

BULLETIN 25-EX-02

TO:             ALL HEALTH INSURERS OFFERING PLANS ON GEORGIA ACCESS

FROM:           JOHN F. KING
                INSURANCE AND SAFETY FIRE COMMISSIONER

DATE:           SEPTEMBER 5, 2025

RE:             CITY OF COLUMBUS V. KENNEDY AND RE-FILING OF 2026 RATES

The Georgia Office of the Commissioner of Insurance and Safety Fire (OCI) is issuing this bulletin
to provide updated guidance regarding the federal court litigation in City of Columbus v. Kennedy.

On September 4, 2025, the Maryland District Court extended the time for the federal government
to respond to its motion for a stay of the preliminary injunction originally issued on August 22,
2025. This extension means the injunction is still in effect, and the provisions of the federal rule
at issue in the case, particularly those concerning Actuarial Value (AV) policies, will not be
implemented for Plan Year 2026 at this time.

As a result, some previously filed health plans for Plan Year 2026 may be out of compliance with
the AV policy as it stands following the injunction. OCI is providing the following guidelines for
re-filing rates to ensure continued compliance.

Re-Filing Guidelines for Qualified Health Plans:
To address the impact of the injunction, OCI will allow a limited re-filing period for certain
Qualified Health Plans (QHPs).
 •    Allowed Re-filings: Only plans that OCI identifies as being out of compliance with the AV
      policy due to the court order will be allowed to re-file. OCI will provide issuers with a specific
      list of these plans.

 •    Permissible Changes: Allowable data changes are only those required to bring the specified
      plans into compliance with the AV policy. Issuers must provide a clear summary of all
      changes made with their re-filing.

 •    Plan Withdrawal Option: Issuers have the option to withdraw non-compliant plans instead of
      re-filing, provided that they will still meet the required metal level offerings in each county
      within their service area after the withdrawal. This option ensures that consumers will still
      have a choice of plans while allowing issuers flexibility.
 •   Re-filing Deadline: OCI requests that carriers submit their re-filings as soon as possible, but
     all re-filings must be received by OCI no later than Friday, September 12, 2025.

OCI will continue to monitor the ongoing litigation and will provide further guidance as necessary.
Small Group plans and off-exchange plans will receive additional information regarding re-filing
in the coming weeks. For any questions regarding this bulletin, please contact OCI at (404) 656-
2070.

                                          JOHN F. KING
                                          INSURANCE AND SAFETY FIRE COMMISSIONER
                                          STATE OF GEORGIA


BULLETIN 25-EX-1: ARBITRATION PANEL EXECUTIVE ORDER

BULLETIN 25-EX-1

TO:          LICENSED ATTORNEYS AND INSURANCE ADJUSTERS IN GEORGIA

FROM:        JOHN F. KING
             INSURANCE AND SAFETY FIRE COMMISSIONER

DATE:        FEBRUARY 19, 2025

RE:          OPEN APPLICATION FOR ARBITRATION PANEL

______________________________________________________________________________

The Commissioner of Insurance is accepting applications from Attorneys and Insurance Adjusters,
licensed in the State of Georiga to be arbitrators for the arbitration panel described below.

To provide procedures for the expeditious and efficient settlement of first-party property damage
claims under peronsal private passenger motor vehicle policies the Commissioner of Insurance
and Safety Fire can establish a panel for arbitration of disputed property damage claims, where
such claims involve total losses. O.C.G.A. § 33-34-8(6); Ga. Comp. R. & Regs. r. 120-2-52-.03(6).
The panel of arbitrators shall consist of attorneys authorized to practice law in this State and
insurance adjusters licensed to act as such in this State. Any panelists selected under this rule will
be chosen from the applications received by the Department.

Applicants need to complete the attached application and provide:

   -    Applicant’s Legal Name
   -    Applicant’s Email Address
   -    Applicant’s Phone Number
   -    Applicant’s Mailing Address
   -    GA Letter of Good Standing (Attorneys)
   -    GA Disciplinary History (Attorneys)
   -    GA License Number and National Producer Number (Adjusters)
   -    Citizenship Affidavit (Form GID-276-GN)

                                       _____________________________________________
                                       JOHN F. KING
                                       INSURANCE AND SAFETY FIRE COMMISSIONER
                             Application for Arbitration Panel
The Commissioner of Insurance is accepting applications from licensed Attorneys and Insurance Adjusters
licensed in the State of Georgia to establish an arbitration panel for disputes related to disputed property claims,
where such claims involve total losses. O.C.G.A.§ 33-34-8(6); Ga. Comp. R & Regs. r. 120-2-52-.03(6).

The panel of arbitrators shall consist of attorneys authorized to practice law in this State and insurance adjusters
licensed to act as such in this State. Attorneys and Adjusters must complete this form and provide the respective
documents requested below to be considered under this rule.

 Applicant Type:                            ☐ Attorney
 (check one)                                ☐ Adjuster
 Legal Name:

 Email Address:

 Phone Number:

 Mailing Address:

 GA License Number:
 (Adjusters only)
 National Producer Number:
 (Adjusters only)

 Enclose Required Documents:                ☐ GA Letter of Good Standing (Attorneys)
 (check all that apply)                     ☐ GA Disciplinary History (Attorneys)
                                            ☐ Citizenship Affidavit - Form GID-276-GN (All Applicants)

Email completed applications and the required supporting document(s) to the Administrative Procedure Division
at ArbitrationPanel@oci.ga.gov. Please include “Arbitration Panel Application” in the subject line.


BULLETIN 24-EX-11: SPECIAL ENROLLMENT PERIOD DECEMBER 21 - DECEMBER 31

BULLETIN 24-EX-11

TO:            ALL INSURERS OFFERING PLANS ON GEORGIA ACCESS

FROM:          JOHN F. KING
               INSURANCE AND SAFETY FIRE COMMISSIONER

DATE:          DECEMBER 20, 2024

RE:            SPECIAL ENROLLMENT PERIOD DECEMBER 21 – DECEMBER 31

The Commissioner of Insurance announces a Temporary Special Enrollment Period (the “SEP”)

for qualified Georgia Access enrollees whose coverage was automatically renewed for Plan Year

2025 after December 1, 2024. This SEP will begin on December 21, 2024, and end on December

31, 2024. Any coverage effectuated during this SEP will have an effective date of January 1, 2025.

                                         JOHN F. KING
                                         INSURANCE AND SAFETY FIRE COMMISSIONER
                                         STATE OF GEORGIA


BULLETIN 24-EX-9: ANNUAL SUBMISSION OF MENTAL HEALTH PARITY COMPARATIVE ANALYSES REPORT

BULLETIN 24-EX-9
TO:       ALL ENTITIES OFFERING HEALTH BENEFIT PLANS IN GEORGIA

FROM: JOHN F. KING
      INSURANCE AND SAFETY FIRE COMMISSIONER

DATE: NOVEMBER 27, 2024

RE:      ANNUAL SUBMISSION OF MENTAL HEALTH PARITY COMPARATIVE
         ANALYSES REPORT

The Official Code of Georgia (O.C.G.A.) § 33-1-27(b)(4) requires health insurers offering
coverage for mental health or substance use disorders as part of a health care plan to comply with
Georgia’s Mental Health Parity Act. Insurers subject to the preceding Code section are required to
submit data on mental health parity and other information designated by the Commissioner on an
annual basis to the Office of the Commissioner of Insurance (OCI).
Insurers that offered coverage for mental health or substance use disorders as part of a health plan
issued in or delivered in the State of Georgia are required to submit a Comparative Analysis Report
(CAR) to the OCI on or before January 1st. Insurer groups wishing to submit a single CAR for
multiple insurance companies may do so as long as each document identifies the applicable
company name and NAIC code.
Companies that filed an Attestation for Annual Reporting MHPAEA Analyses for the prior
reporting year and received approval from the OCI are not required to submit a CAR, unless
coverage issued by the insurer in the State during the current reporting year is now subject to § 33-
1-27.
The OCI has contracted with Regulatory Insurance Advisors, LLC (RIA) to facilitate the collection
and analysis of mental health parity data.

FILING INSTRUCTIONS
To facilitate the collection and analysis of mental health parity data, any questions regarding data
collection     and     mental     health     parity   analysis     should     be    addressed     to
GA_MHPA_DataCall@riaconsulting.net.
When submitting the CAR, please include the following in the email Subject line: “Comparative
Analyses Report,” data year, Company NAIC Code, and Company Name. For example, the
Subject line would be: Comparative Analyses Report, YYYY, NAIC Code 12345 – ABC
Company. This analysis is based on current plan year information.
  Submission          Georgia Code
                                                  Due Date              Where to send
   Required            Reference
                                                              GA Office of Commissioner of
 Comparative    O.C.G.A. § 33-1- 27(b)(4) January 1st or
                                         last business day             Insurance
Analyses Report                                             GA_MHPA_DataCall@riaconsulting.net
                                          prior to deadline

 The following are required for inclusion in the Comparative Analyses Report and resources
 available:

     •   Results of Department of Labor (DOL) Self-Compliance Tool (Refer to resources at:
         https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/mental-health-and-
         substance-use-disorder-parity);
     •   Identified Non-Quantitative Treatment Limitations (NQTL’s) (i.e., prior authorizations,
         reimbursement rates, and exceptions to access to non-network providers).
     •   Factors considered in developing NQTL’s;
     •   Experience/expertise of people developing NQTL’s;
     •   Sources and evidentiary standards utilized to identify NQTL’s. A best practice is to provide
         the entire PDF of the sources and evidentiary standards, including page numbers and sections.
     •   Proof of processes and evidentiary standards used in applying the NQTL’s are comparable
         and no more stringently applied to Mental Health and Substance Use Disorder (MH/SUD)
         and Medical/Surgical benefits as written, and in operation.
     •   Complete, clear and unredacted documentation.
     •   It is unnecessary and inappropriate to put confidential and proprietary information
         protections or statements on any documentation submitted.

 If you have any questions, please contact the Office of the Commissioner of Insurance by email at
 GA_MHPA_DataCall@riaconsulting.net.

                                      JOHN F. KING
                                      INSURANCE AND SAFETY FIRE COMMISSIONER
                                      STATE OF GEORGIA


BULLETIN 24-EX-8: EMERGENCY DISASTER ADJUSTER REQUEST


BULLETIN 26-EX-2: TAX CREDITS FOR CONTRIBUTIONS TO FOSTER CHILD SUPPORT ORGANIZATIONS

BULLETIN 26-EX-2

TO:          ALL ADMITTED INSURERS CONDUCTING BUSINESS IN
             THE STATE OF GEORGIA

FROM:        JOHN F. KING
             INSURANCE AND SAFETY FIRE COMMISSIONER

DATE:        May 29, 2026

RE:         TAX CREDITS FOR CONTRIBUTIONS TO FOSTER CHILD
            SUPPORT ORGANIZATIONS

The purpose of this Bulletin is to inform all insurers conducting business in the state of Georgia
about a provision of House Bill 136 which goes into effect for tax years beginning on or after
January 1, 2026.

The legislation provides for tax credits of up to 30 percent of an insurer’s state insurance premium
tax liability participating in the Qualified Foster Child Support (“QFCS”) Donation Credit, when
applied for between January 1 and June 30 of the year in which the credit will be taken. If there are
aggregate amounts remaining after June 30, a company can apply between July 1 and December 31,
and if approved, 100% of the tax liability can be taken. The state has designated up to $10 million of
the $30 million in annual QFCS tax credits specifically for insurers.

The QFCS Tax Credit Program allows any eligible company to redirect up to 30 percent of their
state tax liability to an approved Qualified Organizations (QO) in order to support foster children
and justice involved youth.

   1. Visit the Department of Revenue’s Georgia Tax Center (GTC) for instruction on
      applying for the QFCS. If you have never filed an income tax return, contact the
      Taxpayer Services Call Center at 877-423-6711.

   2. Claim your Credits
         a. List the earned credits on Section 4 of Form GID-205-PT. The total of section 1-4
             of Form GID-205-PT should be claimed on line 12 of Form GID-012-PT, the
             Georgia Insurance Premium Tax Return. Attach a copy of both the GA DOR
             approval letter and QO acknowledgment to the Return.
         b. Unused credits may be carried forward for up to three years.
____________________________________________________
JOHN F. KING
INSURANCE AND SAFETY FIRE COMMISSIONER
STATE OF GEORGIA


Company Bulletin 2018-10

idoi.illinois.gov; gate-zero IL-a. PARTIAL SET: page-1-per-year harvest; pagination completion pending.


Company Bulletin 2018-09

Illinois Department of Insurance

BRUCE RAUNER                                                                                JENNIFER HAMMER
      dovernor                                                                                Director

TO:               ALL INSURANCE COMPANIES APPROVED TO PROVIDE WORKERS'
                  COMPENSATION INSURANCE CO RAGE     THE STATE OF ILLINOIS

FROM:             Jennifer Hammer, Director of Insuran

DATE:             October 18, 2018

RE:               Company Bulletin #2018-09 Workers' Compensation Rating

The purpose of this Bulletin is to provide guidance for all insurance companies who write workers'
compensation coverage in Illinois if they choose to use rate tiering.

Insurance companies authorized to write workers' compensation insurance in Illinois may establish
multiple rating tiers to price workers' compensation insurance policies. Companies must file all workers'
compensation rates, including multiple rating tiers, with the Illinois Department oflnsurance in accordance
with 215 ILCS 5/456-457 and 50 Ill. Adm. Code Section 2902.

      1. Workers' Compensation Classification Rate Tiering will require:
             a. a filed program used to dete1mine tier placement;
                       1. Tiering should use objective criteria (not subjective).
                      11. Tiering should be applied uniformly across all policyholders.
                     111. When determining rates, the Experience Modification should be considered in
                          the Generalized Linear Model (GLM) and other calculations.
                     1v. Companies filing Tiers should provide a distribution of insureds by Tier.
                      v. Tiering definitions should be fully disclosed to show all factors contributing to
                          the Tiering mechanism.
             b. all rate pages to be filed; and
                       i. completion of the Company Rate Information within the filing.
                      ii. percentage deviation from the licensed rating organizations recommend rate
                          filing for the overall rate adjustment.
             c. all rates are not to be excessive, inadequate or unfairly discriminatory.
                       1. In determining compliance with 456(l)(d): "unfair discrimination exists if, after
                          allowingfor practical limitations, price differentials fail to reflect equitably the
                          difference in expected losses and expenses. A rate is not unfairly discriminatory
                          because different premiums result for policyholders with like exposures but
                          different expenses, or like expenses but different loss exposures, so long as the
                          rate reflects the differences with reasonable accuracy", data collection
                          resource(s) should be provided within the filing.
      2. Proper compliance with all adopted licensed rating organization filings, i.e. statistical data
         reporting in accordance with 50 Ill. Adm. Code Section 2903.

Questions regarding this bulletin may be directed to DOI.InfoDesk@illinois.gov

                                                  320 West Washington St.
                                                Springfield, Illinois 62767-0001
                                                        (217) 782-4515


Company Bulletin 2017-05


Company Bulletin 2017-04


Company Bulletin 2017-01


Company Bulletin 2016-08


Company Bulletin 2016-02

Illinois Department of Insurance

BRUCE RAUNER                                                                ANNE MELISSA DOWLING
   Governor                                                                     Acting Director

TO:           All Insurers

FROM:         Anne Melissa Dowling, Acting Director of Insurance

DATE:         February 5, 2016

RE:           COMPANY BULLETIN CB #2016-02
              ILLINOIS-SPECIFIC SMALL GROUP COMPOSITE PREMIUM METHOD

Family Composite Premiums in the Illinois Small Group Market for Health Benefit Plans
                  Issued or Renewed on or after January 1, 2016

Illinois has allowed the use of family tiered composite premiums in the small group market, and
its use has been well established in the marketplace. Under a tiered composite approach, the
premium levels for all small group employees are derived from the combined rating
characteristics of the entire group, adjusted to allow for the inclusion of an employee’s covered
dependents. The Illinois Department believes that the use of a composite premium
methodology may reduce administrative burdens on issuers and small group employers, will
reduce premium instability for employers and employees, will simplify employee decisions, and
may facilitate defined employer contributions. As the use of composite premiums is also
widespread in the large group market, providing the use of composite premiums for smaller
employers also ensures consistent practices across the entire group market.

The following sections outline the requirements for issuers looking to implement composite
rating methodology in the small group market outside the Federal Marketplace – both for
developing aggregate composite premiums and allocating these premiums to covered
employees and their dependents.

A. Development of Composite Premiums

As required by 45 CFR §147.102(c)(1) and (3), a composite premium must be developed using
a per-member rating methodology. For each covered employee and his/her covered
dependents, the premium must be determined as follows:
   - For each covered child age 0 to 20: Calculate the rate for each of the oldest three
      children by multiplying the base rate by the applicable age and geographic area factors.
      Tobacco use factors must not be applied at this time.
   - For all other individuals: Calculate the rate for each person by multiplying the base rate
      by the applicable age and geographic area factors. Tobacco use factors must not be
      applied at this time.

                                        320 West Washington St.
                                      Springfield, Illinois 62767-0001
                                               (217) 782-4515
                                        http://insurance.illinois.gov
Illinois Department of Insurance
Company Bulletin 2016-02
Page 2 of 4

Age and geographic area are determined at the time that coverage is issued to or renewed
with the group. The composite premium prior to tobacco use surcharges is equal to the sum of
the premiums determined for each covered employee and his/her covered dependents.

B. Allocation of Composite Premiums

Once a composite premium has been calculated, it must be allocated back to covered
employees based on the tier factor applicable to each employee’s family composition. Illinois
requires standard tier definitions and factors for all issuers where tiered composite rating is
used, as follows:
       - Employee only = 1.00
       - Employee + spouse = 2.00
       - Employee + children (including all covered children up to age 26) = 1.85
       - Employee + family (including spouse and all covered children up to age 26) = 2.85
Note that all children under age 26 are considered to meet the definition of “children” for
employee + family and employee + children tiers.

The Weighted Employee Count is equal to the sum of the tier factors determined across all
covered employees. From this the Final Tier Premium prior to tobacco use surcharges can be
calculated as:

      Final Tier Premium = [Group aggregate premium] / [Weighted Employee count]
                               x [Tier factor]

For any employee, the premium applicable can then simply be derived per the formula below:

      Final Employee Premium = Final tier Premium +
                            [Applicable Tobacco Surcharge, if any]

C. Example

As an example of the above approach, consider the following group of employees:
   - Employee A: Employee + spouse + 2 children = Employee + family
   - Employee B: Employee + spouse
   - Employee C: Employee + spouse + 3 children = Employee + family
   - Employee D: Employee + 4 children = Employee + children
   - Employee E: Employee only

For each of the employees, the applicable tier factor is then assigned.
   - Employee A: Employee + family = 2.85
   - Employee B: Employee + spouse = 2.00
   - Employee C: Employee + family = 2.85
   - Employee D: Employee + children = 1.85
   - Employee E: Employee only = 1.00

                                        320 West Washington St.
                                      Springfield, Illinois 62767-0001
                                               (217) 782-4515
                                        http://insurance.illinois.gov
Illinois Department of Insurance
Company Bulletin 2016-02
Page 3 of 4

The Weighted Employee Count can then be derived as follows:

      Weighted employee count = 2.85 + 2.00 + 2.85 + 1.85 + 1.00 = 10.55

Assuming the total monthly premium for the group is $5,275 (prior to any tobacco surcharge),
the Final Tier Premium for each tier can be derived consistent with the formula above.
   - Employee only = 5,275/10.55 x 1.00 = 500
   - Employee + spouse = 5,275/10.55 x 2.00 = 1,000
   - Employee + children = 5,275/10.55 x 1.85 = 925
   - Employee + family = 5,275/10.55 x 2.85 = 1,425

Each employee is then assigned the premium applicable to their tier.
   - Employee A: Employee + family = 1,425
   - Employee B: Employee + spouse = 1,000
   - Employee C: Employee + family = 1,425
   - Employee D: Employee + children = 925
   - Employee E: Employee only = 500
      TOTAL = 1,425 + 1,000 + 1,425 + 925 + 500 = $5,275

The final premium for any employee would be the amount shown above plus any tobacco
surcharges applicable to the employee and his/her covered dependents.

D. Recalculation of Average Monthly Premiums

Throughout a small group’s policy period, employees may come and go and employees may
qualify for special enrollment periods due to various life events. The methodology described
above determines premiums for each tier based on a census of employees and their covered
dependents at the time the group’s policy is issued or renewed. The average monthly premium
for each of the tiers (“Final Tier Premium” above) must remain in effect throughout the entire
policy period and may not increase or decrease to reflect changes in the small group census.
The Final Tier Premium must be recalculated annually, based on the census at the time the
policy is rated.

E. Application of Tobacco Use Factors

The family composite premiums do not include a tobacco use factor. If a tobacco use factor is
used, it must be applied to the specific individual, and is applied to premium applicable to that
individual if per-member rating were applicable (the same amount the member would
contribute to the Development of Composite Premiums as outlined in Section A above). This
additional surcharge is then added to the monthly premium for that individual previously
determined based upon the tier allocation.

                                        320 West Washington St.
                                      Springfield, Illinois 62767-0001
                                               (217) 782-4515
                                        http://insurance.illinois.gov
Illinois Department of Insurance
Company Bulletin 2016-02
Page 4 of 4

For example, assume the spouse of employee C had premium of $600 contributing to the
aggregate $5,275, is a tobacco user, and the carrier has a tobacco use factor of 50%.
   -   The total tobacco surcharge applicable to the spouse of employee C = 50% x $600 =
       $300.
   -   The total premium for employee C and family would be $1,425 + $300 = $1,725.

F. Additional items

   1) The method will be the only permitted composite premium method for new and
      renewing non-grandfathered small group plans in Illinois offered outside the
      marketplace, effective on or after January 1, 2016. Plans offered through the
      marketplace are offered in partnership with the Federal SHOP, which does not currently
      allow for composite premiums to be offered. When the Federal SHOP does implement
      composite premiums, it will only utilize the federal two tiered approach and not the state
      specific composite premium approach utilized outside of SHOP.

   2) This bulletin does not intend to restrict per-member rating in the small group market.
      Per-member premiums will also be permitted.

   3) If an issuer elects to offer the tiered-composite premium methodology in Illinois, the
      issuer is required to offer this option to all small employer groups without regard to size.

Please direct questions regarding this bulletin to Eric Anderson at eric.anderson@illinois.gov.

                                        320 West Washington St.
                                      Springfield, Illinois 62767-0001
                                               (217) 782-4515
                                        http://insurance.illinois.gov


Company Bulletin 2026-08

Illinois Department of Insurance

 JB PRITZKER                                                                             ANN GILLESPIE
   Governor                                                                                Director

TO:               All Illinois Licensed Insurers

FROM:             Ann Gillespie, Director

DATE:             June 29, 2026

RE:               Company Bulletin 2026-08 – Climate Risk Disclosure Survey

In cooperation with chief insurance regulators from American Samoa, California, Colorado,
Connecticut, Delaware, District of Columbia, Guam, Hawaii, Maine, Maryland, Massachusetts,
Michigan, Minnesota, Nevada, New Hampshire, New Jersey, New Mexico, New York, Northern
Mariana Islands, Oregon, Pennsylvania, Puerto Rico, Rhode Island, US Virgin Islands, Vermont,
Virginia, Washington, and Wisconsin, the Illinois Department of Insurance is conducting the Climate
Risk Disclosure Survey for Reporting Year 2025.

For the current survey, Reporting Year 2025, all participating insurers are required to report using the
Task Force on Climate related Financial Disclosure (TCFD)-aligned NAIC Climate Disclosure Risk
Survey. For reporting year 2024, more than 1,800 companies responded to the Survey, capturing over
86% of the entire U.S. insurance market. For guidance on the specific survey sections and questions,
reference the NAIC Climate Risk Disclosure Survey document. Pursuant to P.A. 104-0534, all insurance
companies who are licensed in the State of Illinois and who collected direct written premium amounts of
more than $100 million dollars nationwide during 2025 must respond to the survey.

The completed survey responses are due August 31, 2026. Please register and submit your survey
responses to the Department by going to the survey registration on the interactive web application and
following the registration and submission instructions. Insurance companies have to submit the TCFD-
aligned Climate Risk Disclosure Survey through a PDF document. Companies can use the Survey
Questions document attached to furnish their responses or upload their own TCFD-aligned report. All
responses should be self-contained within a single document, rather than a link to a public
report.

Companies within the same group whose policies and practices are the same and whose answers would
not be materially different from each other may submit uniform group
responses. When submitting group responses, please be certain to check the premium amounts for
each individual company in the group that you are responsible for and submit a document for
each company with more than $100 million in direct written premium nationwide.

In addition to the narrative Climate Risk Disclosure Survey, we invite companies to consider responding
to the following voluntary closed-ended (Y/N) questions on this SurveyMonkey link. The voluntary
closed-ended questions align with the NAIC Climate Risk Disclosure Survey.

           Springfield Office                                                       Chicago Office
        320 W. Washington Street                                              115 S. LaSalle St., 13th Floor
         Springfield, Illinois 62767                                             Chicago, Illinois 60603
              (217) 782-4515                                                        (312) 814-2420
Consistent with previous years, Climate Risk Disclosure Survey responses for the current and prior
years are available to the public and can be found on the California Department of Insurance’s
website. Additional information and guidance related to the survey can also be found on the California
Department’s Climate Risk Disclosure website.

We have also provided a series of webinars on this Survey to build knowledge and capacity within the
insurance sector and insurance companies. You can find the webinars archived at the Climate Risk and
Resiliency Resource Center. We believe that these webinars will offer an excellent opportunity for
participants to enhance their understanding of climate risk disclosure practices and gain practical
knowledge on how to improve their own reporting.

Questions regarding this Company Bulletin should be directed to: DOI.InfoDesk@illinois.gov

Attachment: NAIC Climate Risk Disclosure Survey TCFD-Aligned Questions

           Springfield Office                                                     Chicago Office
        320 W. Washington Street                                            115 S. LaSalle St., 13th Floor
         Springfield, Illinois 62767                                           Chicago, Illinois 60603
              (217) 782-4515                                                      (312) 814-2420
     NAIC CLIMATE RISK DISCLOSURE SURVEY
           TCFD-ALIGNED QUESTIONS
                UPDATED 2022
GOVERNANCE
    1. Disclose the insurer’s governance around climate-related risks and opportunities.
In disclosing the insurer’s governance around climate-related risks and opportunities insurers should
consider including the following:
         • Identify and include any publicly stated goals on climate-related risks and opportunities.
         • Describe where climate-related disclosure is handled within the insurer’s structure, e.g., at a
         group level, entity level, or a combination. If handled at the group level, describe what activities are
         undertaken at the company level.
         A. Describe the board and/or committee responsible for the oversight of climate-related risks and
         opportunities.
In describing the position on the board and/or committee responsible for the oversight of managing the
climate-related financial risks, insurers should consider including the following:
         • Describe the position on the board and/or committee responsible for the oversight of managing
         the climate-related financial risks.
         B. Describe management's role in assessing and managing climate-related risks and opportunities.

STRATEGY
    2. Disclose the actual and potential impacts of climate-related risks and opportunities on the insurer’s
         businesses, strategy, and financial planning where such information is material.
In disclosing the actual and potential impacts of climate-related risks and opportunities on the insurer’s
businesses, strategy and financial planning, insurers should consider including the following:
         • Describe the steps the insurer has taken to engage key constituencies on the topic of climate risk
         and resiliency. *
         • Describe the insurer's plan to assess, reduce, or mitigate its greenhouse gas emissions in its
         operations or organizations. *
         A. Describe the climate-related risks and opportunities the insurer has identified over the short,
         medium, and long term.
In describing the climate-related risks and opportunities the insurer has identified over the short, medium,
and longer term, insurers should consider including the following:
                 • Define short, medium, and long-term, if different than 1-5 years as short term, 5-10 years
                 as medium term, and 10-30 years as long term.
         B. Describe the impact of climate-related risks and opportunities on the insurer’s business, strategy,
         and financial planning.
In describing the impact of climate-related risks and opportunities on the insurer’s business, strategy, and
financial planning, insurers should consider including the following:

           Springfield Office                                                            Chicago Office
        320 W. Washington Street                                                   115 S. LaSalle St., 13th Floor
         Springfield, Illinois 62767                                                  Chicago, Illinois 60603
              (217) 782-4515                                                             (312) 814-2420
               • Discuss if and how the insurer provides products or services to support the transition to a
               low carbon economy or helps customers adapt to climate-related risk.
               • Discuss if and how the insurer makes investments to support the transition to a low
               carbon economy.
       C. Describe the resilience of the insurer’s strategy, taking into consideration different climate-related
       scenarios, including a 2 degree Celsius or lower scenario.

RISK MANAGEMENT
    3. Disclose how the insurer identifies, assesses, and manages climate-related risks.
In disclosing how the insurer identifies, assesses, and manages climate-related risks, insurers
should consider including the following:
         • Describe how the insurer considers the impact of climate related risks on its underwriting
         portfolio, and how the company is managing its underwriting exposure with respect to physical,
         transition and liability risk. *
         • Describe any steps the insurer has taken to encourage policyholders to manage their potential
         physical and transition climate related risks, if applicable. *
         • Describe how the insurer has considered the impact of climate-related risks on its investment
         portfolio, including what investment classes have been considered. *
         A. Describe the insurers’ processes for identifying and assessing climate-related risks.
In describing the insurers’ processes for identifying and assessing climate-related risks, insurers should
consider including the following:
                 • Discuss whether the process includes an assessment of financial implications and how
                 frequently the process is completed. *
         B. Describe the insurer’s processes for managing climate-related risks.
         C. Describe how processes for identifying, assessing, and managing climate-related risks are
         integrated into the insurer’s overall risk management.
In describing how processes for identifying, assessing, and managing climate-related risks are integrated
into the insurer’s overall risk management, insurers should consider including the following:
                 • Discuss whether climate-related risks are addressed through the insurer’s general
                 enterprise-risk management process or a separate process and how frequently the process
                 is completed.
                 • Discuss the climate scenarios utilized by the insurer to analyze its underwriting risks,
                 including which risk factors the scenarios consider, what types of scenarios are used, and
                 what timeframes are considered.
                 • Discuss the climate scenarios utilized by the insurer to analyze risks on its investments,
                 including which risk factors are utilized, what types of scenarios are used, and what
                 timeframes are considered.

METRICS AND TARGETS
   4. Disclose the metrics and targets used to assess and manage relevant collateralized risks and
      opportunities where such information is material.

           Springfield Office                                                           Chicago Office
        320 W. Washington Street                                                  115 S. LaSalle St., 13th Floor
         Springfield, Illinois 62767                                                 Chicago, Illinois 60603
              (217) 782-4515                                                            (312) 814-2420
In disclosing the metrics and targets used to assess and manage relevant collateralized risks and
opportunities where such information is material, insurers should consider including the following:
         • Discuss how the insurer uses catastrophe modeling to manage the climate-related risks to your
         business. Please specify for which climate-related risks the insurer uses catastrophe models to
         assess, if any.
         A. Disclose the metrics used by the insurer to assess climate-related risks and opportunities in line
         with its strategy and risk management process.
In disclosing the metrics used by the insurer to assess climate-related risks and opportunities in line with its
strategy and risk management process, insurers should consider including the following:
                  • In describing the metrics used by the insurer to assess and monitor climate risks, consider
                  the amount of exposure to business lines, sectors, and geographies vulnerable to climate-
                  related physical risks [answer in absolute amounts and percentages if possible], alignment
                  with climate scenarios, [1 in 100 years probable maximum loss, Climate VaR, carbon
                  intensity], and the amount of financed or underwritten carbon emissions.
         B. Disclose Scope 1, Scope 2, and if appropriate, Scope 3 greenhouse gas (GHG) emissions, and the
         related risks.
         C. Describe the targets used by the insurer to manage climate-related risks and opportunities and
         performance against targets.

* Asterisks represent questions derived from the original Climate Risk Disclosure Survey.

            Springfield Office                                                                    Chicago Office
         320 W. Washington Street                                                           115 S. LaSalle St., 13th Floor
          Springfield, Illinois 62767                                                          Chicago, Illinois 60603
               (217) 782-4515                                                                     (312) 814-2420