Company Bulletin 2026-07

Illinois Department of Insurance

 JB PRITZKER                                                                               ANN GILLESPIE
   Governor                                                                                Director

TO:              All Pharmacy Benefit Managers Registered in Illinois and All Illinois Medicaid Managed
                 Care Entities

FROM:            Ann Gillespie, Director

DATE:            May 15, 2026

RE:              Company Bulletin 2026-07 – PDAA Applicability to Medicaid Managed Care Plans

The Illinois Department of Insurance (“Department”) is issuing this bulletin to address the Medicaid-
related applicability of provisions within Section 513b1 of the Illinois Insurance Code (“Code”) (215
ILCS 5/513b1), especially provisions that fall after subsection (f) and before subsection (g).

Since January 1, 2026, pharmacy benefit managers (“PBMs”) and their affiliates have been
required to comply with subsections (f-5) through (f-25) of Section 513b1 of the Code in relation to
Medicaid managed care plans. Additionally, as “insurers” or “health insurers” within the meaning of
Section 513b1(a-5), Medicaid managed care entities and their affiliates directly have been
required to comply with subsections (f-10), (f-20), and (f-25) of Section 513b1.

As added by the Prescription Drug and Affordability Act,1 these subsections establish the following
requirements for the administration of pharmacy benefits under health benefit plans:

       (f-5): “A pharmacy benefit manager or an affiliate acting on its behalf shall not conduct spread
       pricing.”

       (f-10): “A pharmacy benefit manager or an affiliate acting on its behalf shall not steer a covered
       individual. This prohibition also applies to an insurer and its affiliates. Existing agreements entered
       into before the effective date of this amendatory Act of the 104th General Assembly shall
       supersede this subsection until the termination of the current term of such agreement.”

       (f-15): “A pharmacy benefit manager or affiliated rebate aggregator must remit no less than 100%
       of any amounts paid by a pharmaceutical manufacturer, wholesaler, or other distributor of a drug,
       including, but not limited to, rebates, group purchasing fees, and other fees, to the health benefit
       plan      sponsor,      covered       individual,     or      employer.”       The       subsection
       further establishes a PBM reporting requirement to the Department of Insurance and protects
       confidential information received by the Department.

       (f-20): “A pharmacy benefit manager or an affiliate acting on its behalf is prohibited from limiting
       a covered individual's access to drugs from a pharmacy or pharmacist enrolled with the health
       benefit plan under the terms offered to all pharmacies in the plan coverage area by designating the
           Springfield Office                                                         Chicago Office
        320 W. Washington Street                                               115 S. LaSalle Street, 13th Floor
        Springfield, Illinois 62767                                                Chicago, Illinois 60603
             (217) 782-4515                                                            (312) 814-2420
       covered drug as a specialty drug contrary to the definition in this Section. This prohibition also
       applies to an insurer and its affiliates.”

       (f-25) “The contract between the pharmacy benefit manager and the insurer or health benefit plan
       sponsor must allow and provide for the pharmacy benefit manager's compliance with an audit at
       least once per calendar year of the rebate and fee records remitted from a pharmacy benefit
       manager or its affiliated party to a health benefit plan. This audit may be incorporated into the
       audit under paragraph (5) of subsection (b) of this Section. Contracts with rebate aggregators,
       pharmacy services administrative organizations, pharmacies, or drug manufacturers must be
       available for audit by health benefit plan sponsors, insurers, or their designees at least once per
       plan year. Audits shall be performed by an auditor selected by the health benefit plan sponsor,
       insurer, or its designee.” The subsection further requires copies of the report to be provided to the
       PBM and to the Department, affirms the Department’s authority to access books and records
       regardless of any plan sponsor-initiated audit, and protects confidential information received by
       the Department.

In general, Section 513b1 of the Code applies with respect to Medicaid managed care plans: “This Section
applies to contracts entered into or renewed on or after July 1, 2022. Unless provided otherwise in this
Section or in the Illinois Public Aid Code, this Section applies to pharmacy benefit managers that are
contracted with a Medicaid managed care entity on or after January 1, 2026...” 215 ILCS 5/513b1(j).

Additionally, the Code states: “The changes made to this Section by Public Act 104-27 shall apply with
respect to any health benefit plan that provides coverage for drugs that is amended, delivered, issued, or
renewed on or after January 1, 2026.” 215 ILCS 5/513b1(k). The definition of “health benefit plan” refers
to contracts with an “insurer” to pay for the costs of various health benefits, and the definition of “insurer”
expressly includes Medicaid managed care organizations and managed care community networks. 215
ILCS 5/513b1(a) and (a-5).

Section 513b1 of the Code contains only one provision with a Medicaid-related exemption:

       (f) “Unless required by law, a contract between a pharmacy benefit manager or third-party payer
       and a 340B entity or 340B pharmacy shall not contain any provision that:
              ...
              [list of prohibited contractual provisions]
              ...
       As used in this subsection, "pharmacy benefit manager" and "third-party payer" do not include
       pharmacy benefit managers and third-party payers acting on behalf of a Medicaid
       program” (emphasis added).

Because the phrase “this subsection” occurs within subsection (f), the phrase refers to subsection
(f). Subsections (f-5) through (f-25) are different from, and not part of, subsection (f). In fact, subsection
(f) predates the PDAA and was not substantively modified by it.2 Therefore, the “f-dash” subsections are
not affected by the above exemption. All “f-dash” subsections of Section 513b1 of the
Code have applied with respect to Medicaid managed care plans since they took effect on January 1,
2026.

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

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


Company Bulletin 2026-06

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

Illinois Department of Insurance

JB PRITZKER                                                                                ANN GILLESPIE
  Governor                                                                                Director

TO:                All Companies Writing Accident and Health Insurance and Managed Care Plans in Illinois

FROM:              Ann Gillespie, Director

DATE:              May 01, 2026 (REVISED: June 02, 2026)

RE:                COMPANY BULLETIN 2026-06 - Illinois Filing Requirements for Individual and Small Group
                   Health Plans, On and Off-marketplace (On and Off-exchange) and Stand-alone Dental Plans

Please note, items in red below have been amended as of the revised published date of this Company Bulletin.
The Department of Insurance (The Department) is issuing this Bulletin to provide instructions to Issuers seeking
certification or recertification of individual and small group plans and Stand-alone Dental Plans (SADP) offered
on the Individual and Small Business Health Options Program (SHOP) Marketplace. This Bulletin also applies to
those plans offered off the Affordable Care Act (ACA) Marketplace (Off-Exchange) in the individual and small
group markets for Plan Year 2027. Student health plans are required to meet the standards for individual Qualified
Health Plans (QHP) with the exception of filing dates and rating rules. Student health plans must follow the
specific rating and eligibility rules as outlined by Centers for Medicare & Medicaid Services (CMS) for such
plans.
     NOTE: The issuer deadlines apply to ALL individual and small group health plans, and stand-alone
                                  dental plans offered On and Off the Marketplace.
                                           Activity                                                Dates
                   Deadline for New Issuer to Declare Intent to be On-Exchange                   5/15/2026
                   Deadline for Issuers to submit QHP/NQHP Applications to
                                                                                6/3/2026
                   Illinois DOI, including Plan ID Crosswalk data
                   Public Posting of the proposed rates                                          6/10/2026
                   QHP issuer submits the validated Quality Rating System (QRS)
                   clinical measure data, with attestation, to CMS via NCQA’s                    6/15/2026
                                                                 1
  Plan and         Interactive Data Submission System (IDSS)
  Rate             Deadline for issuers to submit their QHP Application Rates Table
                                                                                7/15/2026
  Application      Templates to CMS
  and Review       CMS reviews Rates Table Template data and releases results in the
  Process          Plan Management (PM) Community for issuers and states to Review         7/16/2026 – 8/7/2026

                    Deadline for issuers to submit changes to their QHP Applications                    8/4/2026
                    Plan Preview and Data Correction Window                                       8/15/2026-9/15/2026
                    Get Covered Illinois (GCI) releases certification notices to issuers                9/16/2026
                    Anonymous Shopping Opens                                                           10/13/2026
                    Anticipated public display of QHP quality rating information                       10/13/2026
            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
                               Open Enrollment Begins                                            11/1/2026*

1
 Each QHP issuer must submit and plan-lock its QRS clinical measure data by May 29 to allow the HEDIS®
Compliance Auditor sufficient time to review, approve, and audit-lock all submissions by the June 15 deadline.
There are no fees for QHP issuers associated with accessing and using the IDSS.
*The Department intends to propose a rule change to start Open Enrollment on 10/15 and the Department will
provide an updated notification if that change is adopted.

Issuers are advised to consult federal regulations, the 2027 Final Letter to Issuers released May 28, 2026, and state
law in conjunction with this Bulletin to ensure full compliance. Helpful documents can be found on the
Department’s ACA Issuer Homepage.

    1. All form filings must be submitted in the format of a complete insurance policy. The Department will not
        accept matrix insert page filings, riders, amendments, variable language, or brackets within individual
        (including ACA compliant student health plans) and small group filings. Approved filings will only be
        reopened upon request from CMS. NOTE: Summary of Benefits and Coverage (SBC) may contain
        bracketed information per the federal template, and the cover page may include brackets for policyholder
        name, policy number, product name, effective date of policy and other identifying data.
    2. Issuers are reminded to review all cost-sharing, benefit explanations, limitations and exceptions, listed
        within the SBC, Plan Summary documents and Plan and Benefits Template to ensure all data is displayed
        in a consistent and accurate manner to mitigate avoidable plan display inaccuracies and consumer
        confusion that may result in Special Enrollment Periods.
    3. Issuers are prohibited from utilizing misleading plan marketing names on all forms and/or corresponding
        templates. Specifically, issuers are discouraged from using specific benefit and dollar amount references
        in plan marketing names and templates. All plan marketing name information should be validated to
        ensure accuracy and consistency across the plan or plan variation marketing name, Plans & Benefits
        Template, HealthCare.gov plan selection information, and other applicable QHP certification materials.
    4. Issuers are reminded to use the HIOS module, Marketplace Plan Management System (MPMS). Issuers
        that previously submitted QHP Application data in the Issuer, Benefits & Service Area, Rating, and
        Supplemental Submission Modules within HIOS will instead submit these data in the new HIOS MPMS
        Module to create QHP Applications, submit templates and supporting documents, validate templates, and
        access some QHP Application review results.
    5. For Plan Year 2027 plans, Illinois requires the crosswalk template to be uploaded to the binders. Any
        revised crosswalk submitted to CMS in PM Community, must also be submitted to the state binder in
        System for Electronic Rate and Form Filing (SERFF).
    6. Submit all checklists, templates and supporting documentation in SERFF.
    7. Provide a red-lined version identifying the variations in plan benefit design from the plans submitted for
        the previous plan year for each form filing submitted for recertification. Red-lined versions must be
        submitted under the Supporting Documentation tab in the form filing in SERFF.
    8. Associate all relevant filings in the SERFF binder including, but not limited to, form, rate, external
        review, and network adequacy filings.
    9. Do not include symbols, such as the trademark symbol, in any plan names.
    10. Please note, regardless of any federal flexibility, Get Covered Illinois does not find the following plans to
        be in the interest of qualified individuals or qualified employers in this State under 50 Ill. Adm. Code
        4500.40(d)(2) and will not certify them:
             o Catastrophic plans with terms longer than one year;
             o Non-network QHPs or SADPs;

                                                   Page 2 of 7
        o    REVISED: Plans, including Bronze plans, with a Maximum Out of Pocket Limitation that
             exceeds $12,000 for an individual or $24,000 for a family.
11. The Department requires full updated network adequacy filings to be submitted. Please note, all network
    plans other than most excepted benefits are subject to standards and filing requirements pursuant to 215
    ILCS 124/et seq. as well as 50 Ill. Adm. Code 4540. To the extent that federal law establishes network
    adequacy and transparency standards for stand-alone dental plans in State-based Marketplaces on the
    Federal Platform, the Department will enforce those standards as the operator of the Illinois State-based
    Marketplace. Issuers with planned provider terminations set to take place on or before 1/1/2027 should
    not include those providers within their PY27 Network Filing. For example, if a termination of a network
    agreement will take place 9/1/2026, the issuer should not include those providers within the PY27 filing
    unless the parties have formally executed a renewal of a subsequent contract into PY27. Per the 2027
    Final Letter to Issuers the appointment wait time standards in the 2025 Letter to Issuers remain in effect
    for both medical QHPs and SADPs. NOTE: As a reminder to issuers with network plans, while the
    Department adopted the federal time and distance standards established in Tables 3.1 and 3.2 for medical
    plans and Table 3.3 for SADPs of the 2023 Letter to Issuers; the Department did not adopt the federal
    enrollee accessibility threshold of 90 percent. As previously indicated, issuers who are unable to meet 100
    percent accessibility will be required to complete the Network Adequacy Exception Form (as allowed).
    See item #14 below.
12. Network Adequacy County Facilities Collection Template: This excel document must be accurately
    completed for each applicable network(s) that the plan intends to service. Data collected will identify
    specific contracted Acute Inpatient Hospital and Inpatient or Residential Behavioral Health Facility
    information for each respective county the plan intends to service. This document must accompany the
    Network Adequacy filing. Visit the Accident & Health Checklists section of the Department’s website to
    access and complete the template.
13. QHP Service Area Exception: Issuers that fail to offer coverage to an entire county must obtain an
    exception from the Department. (See QHP Service Area Exception Form) The Issuer must provide
    service area maps to show compliance with the QHP service area requirement.
14. Issuers who are not able to comply with the network adequacy standards for time and distance, provider
    ratio, and appointment wait times are required to complete the with specific details pertaining to the
    known deficiency for the Department’s review and consideration. NOTE: Pursuant to 215 ILCS
    124/10(g) no exceptions may be granted for the requirements set forth in 215 ILCS 124/10(d-5), but
    issuers must still identify and disclose such deficiencies.
15. Remit the fee of $3,000.00 for certification of each new QHP plan and $1,500.00 for recertification for
    each existing QHP plan via EFT in SERFF binder filings at the time of binder submission.
16. For plans that will be terminated, discontinued, or modified, Issuers must submit the appropriate
    notifications pursuant to 215 ILCS 97/30(C) and 215 ILCS 97/50(C). The issuer must also have provided
    advance notice to the Department pursuant 215 ILCS 97/60.
17. Issuers offering individual and small group off-exchange only plans must submit an off-exchange only
    binder submission with all off-exchange only plans following the requirements outlined in this Bulletin.
18. Every plan listed on the Plans & Benefits Template that the Issuer intends to market as a High Deductible
    Health Plan (HDHP) or for use with a Health Savings Account (HSA) must have “HSA-Eligible” checked
    on the template. Issuers are reminded that as a result of H.R. 1 Section 71307, Section 223(c)(2) of the
    Internal Revenue Code was amended to expand the definition of “high deductible health plan” to include
    all individual market qualified health plans available through an Exchange at the catastrophic or bronze
    level of coverage, which grants such plans “HSA-Eligible” status. As clarified by Q&A #6 of IRS Notice
    2026-5, this status applies to individual market catastrophic or bronze plans offered off-Exchange that are
    identical to an individual catastrophic or bronze plan offered through the Exchange, and it even applies to

                                              Page 3 of 7
       “plans sold exclusively off-Exchange without a CSR reduction load that are otherwise identical to plans
       sold on-Exchange with a cost sharing reduction load” (emphasis added). However, this provision does
       not apply to any other plans that are exclusively sold off-Exchange or that are not sold in the individual
       market. Other than an individual market QHP available through an Exchange at the catastrophic or bronze
       level of coverage, no plan with a flat-dollar copayment structure for the entire prescription drug benefit as
       described in 215 ILCS 134/45.3 may be marketed as an HDHP or have the “HSA-Eligible” field checked
       on the template.”
   19. All issuers on the SBM are required to complete the Formulary Compliance Template to assist in the
       evaluation of Illinois specific requirements for prescriptions drugs. The checklist must accompany the
       medical plan’s binder submission under the Supporting Documentation tab in SERFF.Claim Cost
       Distributions for Carriers Participating in the Individual ACA: The Department is considering the
       potential of a reinsurance program for the Individual ACA market through a Section 1332 Waiver. As
       part of the PY2027 rate filing submission, carriers participating in the Individual ACA market are asked
       to provide a member level total allowed cost (carrier paid and member paid prior to risk adjustment and
       any other claim offsets) distribution for calendar year 2024 and 2025. Please bucket the total allowed
       claim costs into $1,000 increments, for example $0-$999, $1,000-$1,999, etc. Provide the count of
       members in each bucket as well as the total allowed cost in each bucket. Please also provide a count of
       members with $0 claims for each year.
   20. PENDING LEGISLATION THAT MAY IMPACT COVERAGE REQUIREMENTS IN PY 2027:
       The Department strongly encourages plans to monitor all pending legislation, including but not limited to
       the following pending bills with effective dates prior to or on January 1, 2027, to ensure compliance for
       coverage:

       HB 3454 would amend Section 356z.33 of the Illinois Insurance Code to substitute the term “epinephrine
       injector” with “epinephrine delivery system” and would incorporate a new definition from the
       Epinephrine Delivery System Act.

       HB 4464 would prohibit DOI-regulated plans - including stand-alone dental plans (SADPs) - from
       requiring dental providers to only accept electronic payments (including virtual cards).

       SB 2838 would place further oversight on DOI-regulated hearing benefit plans and audiology benefit
       managers and enact protections for audiology providers.

       SB 3688 would prohibit DOI-regulated plans from requiring prior authorization or step therapy for
       menopause therapies.

       SB 3707 would give DOI greater oversight of vision benefit managers and vision benefit plan issuers,
       create eye care provider reimbursement parity, and implement consumer protections.

       SB 3815 would prohibit DOI-regulated plans from denying coverage to an individual or employer due to
       a failure to pay premiums under a prior policy or contract. Allows plans to continue collecting past-due
       premiums. Note: this proposal would be effective immediately.

NOTE: Maximum Annual Limitation on Cost Sharing for Plan Year 2027 for IL

                                               Individual Coverage                     Family Coverage
 Health Plans                                        $12,000                                $24,000
                                                  Page 4 of 7
 SADPs                                                  $450                                   $900

Exhibit 1:

2027 Health Plans Filing Requirements – Form and Binder

                                                                Required Submission Via
                                                                         SERFF
                                                                  On/Off-        Off-
               Federal Required Templates                                                              Location
                                                                 Exchange     Exchange
  All Applicable templates/documents listed on the CMS
                                                                    Yes              Yes                Binder
                  Certification Checklist
             Illinois Required Documents
     ACA Individual, Small Group, and Catastrophic
                                                                    Yes              Yes              Form filing
                         Checklist
   ACA Individual and Small Group SADP Checklist                    Yes              Yes           Form filing
      Network Adequacy and Transparency Checklist                                                   Network
                                                                    Yes              Yes
                   (Including SADPs)                                                             Adequacy Filing
     Mental Health Parity Supporting Documentation
                                                                    Yes              Yes            Form Filing
           Template (does not include SADP)
                                                                                Binder
               Proposed Enrollment Template                         Yes              Yes

                 External Review Checklist                                                       External Review
                                                                    Yes              Yes
                 (Not applicable to SADPs)                                                            Filing

QHP Rates Guidance:
CMS and the National Association for Insurance Commissioners (NAIC) have established a system connection
between the SERFF and the Health Insurance Oversight System Unified Rate Review (HIOS URR) module.

All new filings created AFTER 3/25/22 should be submitted using the new SERFF to URR Transfer Process. This
is done by using the new URRT Tab in SERFF. For the rate filing in SERFF, the URRT, Part II Written
Justification (if required), federal Actuarial Memorandum, and redacted federal Actuarial Memorandum should
only be included on the URRT Tab (not on other tabs).

If an issuer enters their rate submission incorrectly through HIOS instead of SERFF, CMS will deactivate that
submission and notify the issuer that it must be entered through the SERFF Transfer Process.

Two tutorial videos are below:
       • URRT tab/filing submission (17 minutes)
                    ▪ https://naic.webex.com/naic/ldr.php?RCID=8fdd279b684dd81e95f1ed6576bdee6d
       • URRT Responses/Amendments (6 minutes)
                    ▪ https://naic.webex.com/naic/ldr.php?RCID=dc62c787e0658801e981c296b1bdfe52

    1. The Department will allow carriers to modify their individual and small group rate filings through July
       10, 2026 to reflect updated assumptions related to risk adjustment. Other types of changes or changes
       after this date will be allowed at the discretion of the Department. All documents that change will need to
       be resubmitted in redline format to allow for a more efficient review.
    2. Since July 1, 2019, it has been illegal in Illinois to sell tobacco products to individuals under 21 years of
                                                   Page 5 of 7
         age. Accordingly, premium rates for consumers in this age group should not include a tobacco load.
    3.   Actuarial memorandums must include the commission schedules and any recent or anticipated changes
         thereto.
    4.   Actuarial memorandums must include a description of the state mandates included in the rate filing and
         the pricing impact of each mandate.
    5.   Actuarial Value (AV) screenshots should be included in the rate filing and a summary of the AV
         calculator output should be provided in Excel.
    6.   Carriers offering QHPs in the individual market are required by 215 ILCS 5/355(c-5) to apply a cost-
         sharing reduction defunding factor for on-exchange Silver plans within the range of 1.26 to 1.33. The
         factor for other plans should be 1.00. NOTE: This guidance is subject to change depending on federal
         law.
    7. Carriers offering QHPs in the individual market are required by 215 ILCS 5/355(c-5) to apply induced
       demand factors based on the formula: (Plan Actuarial Value) ^ 2 - (Plan Actuarial Value) +1.24. Please
       use the pricing AV for the base plan including (or adjusted for) the CSR load. The induced demand
       factor should be consistent between the index rate and the plan-adjusted index rate.
    8. If any other rate adjustment factors apply, please provide narrative and quantitative support detailing all
       assumptions as well as explain where the adjustment is applied.

Public Posting of Initial Rate Filings:

As a result of Public Act 103-0106, the initial rate filings received by the Department will be publicly posted on
the Department’s website within 5 business days of the rate filing deadline. Pursuant to the recently amended 50
Ill. Adm. Code 2026.50(c)(2), regardless of any increase, decrease, or continuation in rates, submitted rate filing
summary templates must include all information described in 50 Ill. Adm. Code 2026.50(e). An Excel template
titled “Plan Year 2027 Public Rate Filing Summary.xlsx” accompanies this Bulletin and is to be completed by
issuers summarizing the rate filing. Please only complete the shaded areas of the Rate Filing Summary template.
All shaded areas are required to be completed except for “Any Other Relevant Comments (optional)”.

The rate filing summary templates and other public portions of the rate filing will be posted to the Department’s
website to fulfill this statutory requirement. If an issuer intends to offer both individual and small group coverage,
a separate template for each should be submitted as part of the supporting documentation in each filing.

Aside from the summary templates, which are not eligible for redaction, if the QHP issuer deems any rate filing
information to be proprietary, privileged, or confidential such that disclosure of the information would cause
competitive harm to the issuer, the QHP issuer must file both 1) an unredacted version and 2) a version with the
deemed confidential information redacted that is separately marked for public access in SERFF. Additionally, to
qualify for ongoing exemption from production under Section 7(1)(g) of the Freedom of Information Act [5 ILCS
140], proprietary, privileged, or confidential information must be furnished to the Department with the explicit
claim that the disclosure of the information would cause competitive harm to the issuer. The issuer must furnish
that claim in a letter separate from the substantive rate filing documents but within the same SERFF filing.

The posting of the rate filings to the Department’s website will start a 30-day public comment period where
comments may be submitted to the Department of Insurance. The comments received will then be posted to the
Department’s website.

                                                    Page 6 of 7
The deadlines for small group quarterly rate filings are:
Effective Date          Due Date
April 1, 2027           November 17, 2026
July 1, 2027             February 16, 2027
October 1, 2027         May 19, 2027

Small group quarterly rate filings will also be posted on the DOI website for public comment.

Exhibit 2:

2027 Health Plans Filing Requirements – Rates
                                                               Required Submission via
                                                                      SERFF

                                                                                Off-
               Federal Required Templates                    On-Exchange                           Location
                                                                                Exchange
              QHP Rating Module Documents
                                                                                Rate filing &
                 • Rates Table Template                           Yes              Yes
                                                                                Binder

                                                                                Rate Filing &
              Unified Rate Review Template                        Yes              Yes
                                                                                Binder
               Illinois Required Documents
                                                                                Rate Filing &
              Health Premium Rate checklist                       Yes              Yes
                                                                                Binder
                                                                                Yes          Rate Filing &
              Proposed Enrollment Template                        Yes
                                                                                Binder

Illinois Health Rate Filing Web Portal:

The Department is sunsetting the Illinois Health Rate Filing Web Portal. Therefore, effective immediately,
carriers are no longer required to submit rates to the Illinois Health Rate Filing Web Portal.

Reminders:
   • The Department requires issuers to submit the applicable federal QHP templates for all off-exchange only
      non-QHP individual and small group filings via a separate off-exchange only Binder submission.
   • Network adequacy testing extends to all ACA products, including both individual and small group, with
      federal requirements in place as of PY 2027.

                                                    Page 7 of 7


Company Bulletin 2026-05

Illinois Department of Insurance

    JB PRITZKER                                                                              ANN GILLESPIE
      Governor                                                                                Director

TO:                  All Health Insurance Issuers Writing Accident and Health Insurance, Health Maintenance
                     Organization Health Care Plans, Limited Health Care Plans, and Voluntary Health
                     Services Plans

FROM:                Ann Gillespie, Director

DATE:                April 3, 2026

RE:                  Company Bulletin 2026-05 Biomarker Testing Coverage Requirements

The purpose of this bulletin is to inform, clarify, and promote uniformity in the application of the
biomarker testing coverage as required by 215 ILCS 5/356z.46.

Background:

The Department has received inquiries and complaints indicating that some issuers may not be providing
coverage for biomarker testing to the extent required by Public Act 102-0203, 1 which is codified as 215
ILCS 5/356z.46. P.A. 102-0203 requires all group and individual accident and health insurance policies,
HMO health care plans, and limited health care plans or voluntary health services plans that cover
laboratory services, which are amended, delivered, issued, or renewed on or after January 1, 2022, to
provide coverage for biomarker testing pursuant to criteria established under Section 356z.46(d). This
bulletin serves as a reminder of issuers’ obligations under this statute.

Scope of Biomarker Testing Coverage:

The statute relies on the following definitions:

           “Biomarker” means “a characteristic that is objectively measured and evaluated as an indicator
           of normal biological processes, pathogenic processes, or pharmacologic responses to a specific
           therapeutic intervention” and includes, but is not limited to, gene mutations or protein
           expression.

           “Biomarker testing” means the analysis of a patient’s tissue, blood, or fluid biospecimen for the
           presence of a biomarker. “Biomarker testing” includes, but is not limited to, single-analyte tests,
           multiplex panels, and partial or whole genome sequencing. 215 ILCS 5/356z.46(a).

Under Section 356z.46(c), biomarker testing, including, but not limited to, single-analyte tests, multiplex
panels, and partial or whole genome sequencing tests, “must be covered and conducted in an efficient

1
    Illinois General Assembly - Public Act 102-0203
               Springfield Office                                                       Chicago Office
            320 W. Washington Street                                             115 S. LaSalle Street, 13th Floor
            Springfield, Illinois 62767                                              Chicago, Illinois 60603
                 (217) 782-4515                                                          (312) 814-2420
manner to provide the most complete range of results to the patient’s health care provider without
requiring multiple biopsies, biospecimen samples, or other delays or disruptions in patient care.”

The law requires coverage for biomarker testing “for the purposes of diagnosis, treatment, appropriate
management, or ongoing monitoring of an enrollee's disease or condition when the test is supported by
medical and scientific evidence” as further described in Section 356z.46(d).

In the event coverage is restricted, Section 356z.46(e) requires issuers to maintain a clear, readily
accessible, and convenient process for patients and prescribing practitioners to request an exception,
which must be available on the issuer’s website.

Issuers should review and update medical policies and billing practices as appropriate to ensure
coverage aligns with current evidence-based recommendations in the statutorily listed sources for
biomarker testing.

Issuers retain the right to determine and deny claims for biomarker testing based on medical necessity
only if compliant with Section 356z.46 of the Illinois Insurance Code.

Issuers are required to use only current definitions and coverage requirements.

Issuers are required to render a biomarker coverage decision in a timely manner under existing laws.
E.g., 215 ILCS 5/154.6(c), (i), (m), (o); 215 ILCS 5/368a(c); 215 ILCS 200/25 and 200/30; and 50 Ill.
Adm. Code 919.50(a).

Please direct questions regarding this Bulletin to DOI.InfoDesk@illinois.gov.

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


Company Bulletin 2022-17

Illinois Department of Insurance

 JB PRITZKER                                                                   DANA POPISH SEVERINGHAUS
   Governor                                                                             Director

TO:              All Companies with Current or Historical Individual Business in Illinois

FROM:            Dana Popish Severinghaus, Director
                 Illinois Department of Insurance

DATE:            November 2, 2022

RE:              Company Bulletin 2022-17 – Health Insurance Data Call Due November 23, 2022

Oliver Wyman is working with the Illinois Department of Insurance (the Department) to collect data for
a study as required per Public Act 102-0900 (the Health Insurance Coverage Premium Misalignment
Study Act). Companies who have offered, or will be offering, coverage in the individual market in
Illinois in 2019, 2020, 2021, 2022, or 2023 are included in this data call.

Please see the template (‘General Info & Instructions’ tab) for instructions on how to complete the
required items and submit the data to Oliver Wyman. The data requested by this data call is due
November 23, 2022.

All information provided by the companies will be kept confidential with the exception that aggregated
information may be made publicly available as part of the Department’s analysis.

All inquiries related to this data call should be directed to John Rienstra
john.rienstra@oliverwyman.com, Gabe Rivera at gabe.rivera@oliverwyman.com, and/or Peter
Kaczmarek at peter.kaczmarek@oliverwyman.com.

           Springfield Office                                                        Chicago Office
        320 W. Washington Street                                              122 S. Michigan Ave., 19th Floor
        Springfield, Illinois 62767                                               Chicago, Illinois 60603
             (217) 782-4515                                                           (312) 814-2420


2004-09 Credit Insurance Sold by Motor Vehicle Dealers

mass.gov ToU: public records can be copied and used for any purpose; gate-zero TOP-20 MA row. Akamai 403s custom UA strings — fetched UA-less with From header.


2004-04 Amendment to Bulletin 2003-01 Regarding an Insurer's Right to Restrict Use of General Account Fixed Accounts Within Variable Annuity Contracts


2005-01 Massachusetts Form and Rate Filing Requirements and Procedures to Supplement Bulletin 2004-10 Regarding Uncertainty Related to Expiration of the Terrorism Risk Insurance Act of 2002 ('TRIA')


2004-10 Uncertainty Related to Expiration of the Terrorism Risk Insurance Act of 2002 (TRIA) Exclusions Related to Acts of Terrorism


2004-07 Amendments to Laws Mandating Coverage for Early Intervention Services for Dependent Children


2004-05 Individual Annuity Filing Requirements for the New Provision Created With Chapter 59 of the Acts of 2004 for Determining Minimum Nonforfeiture Amounts for Individual Annuities


2005-05 Workers' Compensation Self-Insurance Groups


2005-03 Changes in Requirements for Licensed Foreign Insurers Transacting Business in Massachusetts


2004-12 Changes in the Requirements for Workers Compensation Insurers Doing Business in Massachusetts


2004-11 Addendum to 2004 Guide to Health Insurance for People with Medicare


2004-08 The Deregulation of Certain Commercial Contracts of Insurance Pursuant to Chapter 146 of the Acts of 2004


2004-03 Long-Term Care Policies that are Intended to Satisfy Minimum Coverage Requirements for Certain MassHealth Exemptions


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Chapter 10 Complaint Investigation and Determination Process | Library of Maryland Regulations

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                   Subtitle 16 MISCELLANEOUS

                   Chapter 10 Complaint Investigation and Determination Process

             Code of Maryland Regulations

                 Chapter 10 Complaint Investigation and Determination Process

                       .01 Scope.

                       .02 Definitions.

                       .03 Complaint investigation.

                       .04 Determination.

                       .05 Reporting.

                       .06 Information.

                       .07 Commissioner’s Actions.

                       .08 Sanctions.

                       .09 Hearings.

                   Administrative History
                   Effective date: November 12, 2012 (39:22 Md. R. 1430)
                   Authority
                    Insurance Article, §2-109(a) ; Health-General Article, §19-705(a)(2); Annotated Code of Maryland

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                 Subtitle 17 MARYLAND HEALTH INSURANCE PLAN

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Chapter 04 Senior Prescription Drug Assistance Program | Library of Maryland Regulations

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                   Subtitle 17 MARYLAND HEALTH INSURANCE PLAN

                   Chapter 04 Senior Prescription Drug Assistance Program

             Code of Maryland Regulations

                 Chapter 04 Senior Prescription Drug Assistance Program

                   Administrative History
                   Effective date:
                   Regulations .01—.08 adopted as an emergency provision effective July 1, 2000 (27:15 Md. R. 1397); emergency status amended and extended at 28:3 Md. R. 202; adopted permanently effective April 16, 2001 (28:7 Md. R. 689)
                   ——————
                   Chapter revised as an emergency provision effective July 1, 2001 (28:16 Md. R. 1480); revised permanently effective October 15, 2001 (28:20 Md. R. 1782)
                   ——————
                   Chapter revised and recodified from  10.09.28  Senior Assistance: Short-Term Prescription Drug Subsidy Program, to  31.17.04  Senior Prescription Drug Program, as an emergency provision effective July 1, 2003 (30:14 Md. R. 934); revised and recodified permanently effective December 22, 2003 (30:25 Md. R. 1851)
                   ——————
                   Chapter revised effective October 8, 2007 (34:20 Md. R. 1742)
                   Regulation .01B amended effective August 10, 2009 (36:16 Md. R. 1252)
                   Regulation .02A, B amended effective August 10, 2009 (36:16 Md. R. 1252)
                   ——————
                   Chapter recodified from  31.17.04  Senior Prescription Drug Assistance Program, to  10.09.60  Senior Prescription Drug Program effective July 1, 2016

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                 Chapter 03 Operation and Administration of the Plan

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                 Title 32 MARYLAND DEPARTMENT OF AGING

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Chapter 06 Bulk Reinsurance, Stock, and Mutual Insurers | Library of Maryland Regulations

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                   Chapter 06 Bulk Reinsurance, Stock, and Mutual Insurers

             Code of Maryland Regulations

                 Chapter 06 Bulk Reinsurance, Stock, and Mutual Insurers

                       .01 Reinsurance Agreement.

                   Administrative History
                   Effective date: March 25, 1966
                   Amended effective May 1, 1968
                   ——————
                   Chapter recodified from COMAR 09.30.41 to  COMAR 31.16.06  effective September 7, 1998 (25:18 Md. R. 1439)
                   Authority
                   Insurance Article, §§ 2-109  and  3-124 , and  3-125 , Annotated Code of Maryland

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                 Chapter 05 Cancellation of Insurance Contracts by Premium Finance Companies [Repealed]

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                 Chapter 07 Holocaust Victims Insurance Claims and Reports [Repealed]

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Chapter 09 Registry and Report on Slavery Era Insurance | Library of Maryland Regulations

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                   Title 31 MARYLAND INSURANCE ADMINISTRATION

                   Subtitle 16 MISCELLANEOUS

                   Chapter 09 Registry and Report on Slavery Era Insurance

             Code of Maryland Regulations

                 Chapter 09 Registry and Report on Slavery Era Insurance

                       .01 Purpose.

                       .02 Definitions.

                       .03 Reporting Insurers.

                       .04 Report Format and Content.

                       .05 Submission.

                       .06 Availability of the Slavery Era Insurance Policy Registry and Report.

                       .07 Enforcement.

                   Administrative History
                   Effective date: December 28, 2009 (36:26 Md. R. 1999)
                   Authority
                   Insurance Article, §§ 2-109 (a)( 1 ) and  30-102 (c), Annotated Code of Maryland

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                 Chapter 08 Privacy of Consumer Financial and Health Information

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                 Chapter 10 Complaint Investigation and Determination Process

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Chapter 02 Medically Uninsurable Individual Based on a Medical or Health Condition | Library of Maryland Regulations

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                   Subtitle 17 MARYLAND HEALTH INSURANCE PLAN

                   Chapter 02 Medically Uninsurable Individual Based on a Medical or Health Condition

             Code of Maryland Regulations

                 Chapter 02 Medically Uninsurable Individual Based on a Medical or Health Condition

                       .01 Purpose.

                       .02 Definitions.

                       .03 Proof of a Medical or Health Condition.

                   Administrative History
                   Effective date:
                   Regulations  .01 — .03  adopted as an emergency provision effective February 6, 2003 (30:5 Md. R. 365); adopted permanently effective August 4, 2003 (30:15 Md. R. 993)
                    Regulation .02B  amended effective January 30, 2006 (33:2 Md. R. 85); May 5, 2008 (35:9 Md. R. 900); December 29, 2008 (35:26 Md. R. 2251)
                   Authority
                   Insurance Article, §§ 14-501 (h)( 1 )(iv) and  14-503 (k), Annotated Code of Maryland

                 Previous
                 Chapter 01 Plan Administrator Criteria

                 Next
                 Chapter 03 Operation and Administration of the Plan

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Chapter 03 Operation and Administration of the Plan | Library of Maryland Regulations

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                   Subtitle 17 MARYLAND HEALTH INSURANCE PLAN

                   Chapter 03 Operation and Administration of the Plan

             Code of Maryland Regulations

                 Chapter 03 Operation and Administration of the Plan

                       .01 Purpose.

                       .02 Definitions.

                       .03 Board Meetings.

                       .04 Executive Director.

                       .05 Independent Consultants.

                       .06 Plan Administrator.

                       .07 Hospital Assessments.

                       .08 Investment of Fund Assets.

                       .09 Determination of Plan Benefits and Plan Structure.

                       .10 Determination of Plan Premium.

                       .10-1 Low-Income Subsidy.

                       .11 Evaluation of Plan.

                       .12 Marketing of Plan.

                       .13 Certificates of Coverage.

                       .14 Eligibility Requirements.

                       .15 Plan Enrollment Procedures.

                       .16 Preexisting Condition Limitations.

                       .17 Termination of Coverage.

                       .18 Coordination of Benefits With Other Coverage.

                       .19 Complaints.

                   Administrative History
                   Effective date:
                   Regulations  .01 — .19  adopted as an emergency provision effective April 8, 2003 (30:9 Md. R. 609); emergency text amended effective July 1, 2003 (30:16 Md. R. 1072); adopted permanently effective December 22, 2003 (30:25 Md. R. 1851)
                   Regulation .01B amended effective May 21, 2007 (34:10 Md. R. 891)
                    Regulation .02B  amended effective February 22, 2010 (37:4 Md. R. 343); August 9, 2010 (37:16 Md. R. 1060); January 7, 2013 (39:26 Md. R. 1666)
                    Regulation .10E  amended effective January 7, 2013 (39:26 Md. R. 1666)
                    Regulation .10-1  adopted effective May 21, 2007 (34:10 Md. R. 891)
                    Regulation .12C  amended effective January 30, 2006 (33:2 Md. R. 85)
                    Regulation .14  amended effective May 4, 2009 (36:9 Md. R. 654); February 22, 2010 (37:4 Md. R. 343)
                   Authority
                    Insurance Article, §14-503(k),  Annotated Code of Maryland

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Chapter 04 Provision of Completed Premium Finance Agreement to Insured | Library of Maryland Regulations

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                   Subtitle 16 MISCELLANEOUS

                   Chapter 04 Provision of Completed Premium Finance Agreement to Insured

             Code of Maryland Regulations

                 Chapter 04 Provision of Completed Premium Finance Agreement to Insured

                       .01 When Insured Is Present at Time of Signing.

                       .02 When Insured Is Not Present at Time of Signing.

                       .03 Records.

                   Administrative History
                   Effective date: March 15, 1993 (20:5 Md. R. 513)
                   ——————
                   Chapter recodified from COMAR 09.30.79 to  COMAR 31.16.04  effective September 7, 1998 (25:18 Md. R. 1439)
                   Authority
                   Insurance Article, §§ 2-109 ,  23-103 ,  23-207 , and  23-302 (c), Annotated Code of Maryland

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                 Chapter 03 Title Insurance Companies — MAHT Account

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                 Chapter 05 Cancellation of Insurance Contracts by Premium Finance Companies [Repealed]

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Chapter 05 Cancellation of Insurance Contracts by Premium Finance Companies [Repealed] | Library of Maryland Regulations

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                   Title 31 MARYLAND INSURANCE ADMINISTRATION

                   Subtitle 16 MISCELLANEOUS

                   Chapter 05 Cancellation of Insurance Contracts by Premium Finance Companies [Repealed]

             Code of Maryland Regulations

                 Chapter 05 Cancellation of Insurance Contracts by Premium Finance Companies [Repealed]

                   Administrative History
                   Effective date: November 23, 1992 (19:23 Md. R. 2040)
                   ——————
                   Chapter recodified from COMAR 09.30.87 to  COMAR 31.16.05  effective September 7, 1998 (25:18 Md. R. 1439)
                   ——————
                   Regulation .01 repealed effective February 15, 2016 (43:3 Md. R. 274)

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Chapter 07 Holocaust Victims Insurance Claims and Reports [Repealed] | Library of Maryland Regulations

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                   Subtitle 16 MISCELLANEOUS

                   Chapter 07 Holocaust Victims Insurance Claims and Reports [Repealed]

             Code of Maryland Regulations

                 Chapter 07 Holocaust Victims Insurance Claims and Reports [Repealed]

                   Administrative History
                   Effective date: June 25, 2001 (28:12 Md. R. 1118)
                   ——————
                   Regulations .01—.09 repealed effective February 15, 2016 (43:3 Md. R. 274)

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Chapter 08 Privacy of Consumer Financial and Health Information | Library of Maryland Regulations

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                   Title 31 MARYLAND INSURANCE ADMINISTRATION

                   Subtitle 16 MISCELLANEOUS

                   Chapter 08 Privacy of Consumer Financial and Health Information

             Code of Maryland Regulations

                 Chapter 08 Privacy of Consumer Financial and Health Information

                       .01 Scope.

                       .02 Purpose.

                       .03 Definitions.

                       .04 Exemption from Notice and Opt Out Requirements for Nonpublic Personal Financial Information.

                       .05 Initial Privacy Notice for Financial Information to Consumers Required.

                       .06 Annual Privacy Notice for Financial Information to Customers Required.

                       .07 Information To Be Included in Privacy Notices for Financial Information.

                       .08 Form of Opt Out Notice to Consumers and Opt Out Methods.

                       .09 Revised Privacy Notices for Financial Information.

                       .10 Delivery of Privacy Notices for Financial Information.

                       .11 Limits on Disclosure of Nonpublic Personal Financial Information to Nonaffiliated Third Parties.

                       .12 Limits on Redisclosure and Reuse of Nonpublic Personal Financial Information.

                       .13 Limits on Sharing Account Number Information for Marketing Purposes.

                       .14 Exception to Opt Out Requirements for Disclosure of Nonpublic Personal Financial Information for Service Providers and Joint Marketing.

                       .15 Exceptions to Notice and Opt Out Requirements for Disclosure of Nonpublic Personal Financial Information for Processing and Servicing Transactions.

                       .16 Other Exceptions to Notice and Opt Out Requirements for Disclosure of Nonpublic Personal Financial Information.

                       .17 When Authorization Required for Disclosure of Nonpublic Personal Health Information.

                       .18 Authorizations for Disclosure of Health Information.

                       .19 Authorization Request Delivery.

                       .20 Relationship to Federal Rules.

                       .21 Relationship to Maryland Laws.

                       .22 Protection of Fair Credit Reporting Act.

                       .23 Nondiscrimination.

                       .24 Effective Date.

                   Administrative History
                   Effective date: January 21, 2002 (29:1 Md. R. 26)
                    Regulation .06  amended effective February 27, 2017 (44:4 Md. R. 256)
                   Authority
                    Insurance Article, §2-109(d),  Annotated Code of Maryland

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Chapter 01 Plan Administrator Criteria

Chapter 01 Plan Administrator Criteria | Library of Maryland Regulations

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                   Subtitle 17 MARYLAND HEALTH INSURANCE PLAN

                   Chapter 01 Plan Administrator Criteria

             Code of Maryland Regulations

                 Chapter 01 Plan Administrator Criteria

                       .01 Scope.

                       .02 Definitions.

                       .03 Selection Criteria for Plan Administrator.

                   Administrative History
                   Effective date:
                   Regulations  .01 — .03  adopted as an emergency provision effective February 6, 2003 (30:5 Md. R. 365); adopted permanently effective August 4, 2003 (30:15 Md. R. 993)
                   Authority
                    Insurance Article, §14-506(a),  Annotated Code of Maryland

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Chapter 07 Limited Benefits Policies — Reporting Requirements [Repealed] | Library of Maryland Regulations

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                   Subtitle 10 HEALTH INSURANCE — GENERAL

                   Chapter 07 Limited Benefits Policies — Reporting Requirements [Repealed]

             Code of Maryland Regulations

                 Chapter 07 Limited Benefits Policies — Reporting Requirements [Repealed]

                   Administrative History
                   Effective date: December 21, 1992 (19:25 Md. R. 2205)
                   ——————
                   Chapter recodified from COMAR 09.30.92 to  COMAR 31.10.07  effective September 7, 1998 (25:18 Md. R. 1439)
                   Chapter repealed effective October 5, 1998 (25:20 Md. R. 1534)

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                 Chapter 06 Standards for Medicare Supplement Policies

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                 Chapter 08 Limited Benefits Policies — Minimum Loss Ratio [Repealed]

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21-01 - Updated Disaster Contact Information, January 14, 2021

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INSURANCE BULLETIN 21-01
          Updated Disaster Contact Information

          Issued: January 14, 2021

The following Bulletin is issued by the Missouri Department of Commerce and Insurance (“Department”) to
inform and educate the reader on the specified issue. It does not have the force and effect of law, is not an
evaluation of any specific facts or circumstances, and is not binding on the Department. See section 374.015,
RSMo.

To:              All insurers issuing policies covering real or personal property in Missouri

From:            Chlora-Lindley Myers, Director

Re:              Updated Disaster Contact Information

In anticipation of the upcoming spring storm season, and to ensure prompt and efficient communications with
the insurance industry following a disaster, the DCI requests each insurer insuring real or personal property in
the state to provide the following contact information to the DCI:

         Primary regulatory contact: This contact should be available to directly communicate with the
          Director and senior DCI leadership following a disaster within the state. These would be high-level
          communications about the DCI’s response efforts, the company’s response efforts, logistic issues and
          other urgent regulatory matters following a disaster.
      Secondary regulatory contact: This secondary contact should be able to discuss non-urgent regulatory
       issues with DCI staff as well as participate in industry conference calls and meetings regarding disaster
       response matters.

      Communications contact: This contact should be available to discuss inquiries received from press
       outlets and to coordinate joint communication and consumer outreach efforts.

For each insurer contact type identified above, the DCI is requesting contact information (name, title telephone
numbers, email address) be submitted on the accompanying Excel spreadsheet form. Responses can be emailed
to CompanyContacts@insurance.mo.gov

Where there are multiple insurers within a larger group, a single response may be submitted if the individuals
identified for the larger group can speak to the issues identified above for each insurer within the group.

Any questions or comments regarding this Bulletin should be directed to Samantha Mueller at 573-751-2430 or
via email to Samantha.Mueller@insurance.mo.gov


26-09 - Post Storm Cancellations and Non-Renewals, May 29, 2026

DEPARTMENT OF COMMERCE & INSURANCE
                         P.O. Box 690, Jefferson City, Mo. 65102-0690

             INSURANCE BULLETIN 26-09
             Post Storm Cancellations and Non-Renewals
             Issued: May 29, 2026
The following Bulletin is issued by the Missouri Department of Commerce
and Insurance ("Department'? to inform and educate the reader on the
specified issue. It does not have the force and effect of law, is not an
evaluation of any specific facts or circumstances, shall not be considered a
statement of general applicability and is not binding on the Department.
See§ 374.015, RSMo (2016).

  To:        All property and casualty insurers writing homeowners and dwelling
             insurance covering residential properties and Condominium Master
             Policies
  From:      Angela L. Nelson, Director

  Re:        Post Storm Policy Non-Renewals and Cancellations

Following last year's devastating severe storm and tornado events, Governor Kehoe
issued a series of Executive Orders, declaring a State of Emergency in the State of
Missouri.
Based upon that State of Emergency, the significant effort and resources required for
Missourians to recover from these events and based upon inquiries and requests
received, the Department issued Bulletin 25-10 and Bulletin 25-11. These Bulletins
requested insurers to cease issuing cancellations and non-renewals on properties that
were damaged by a storm anywhere within Missouri after March 1, 2025. The
Department acknowledges and appreciates the insurance industry’s broad cooperation
with those requests.

The State of Emergency, as declared and extended under Executive Order 26-13, is set
to expire on May 31, 2026 and will not be extended further. As such, this Bulletin
hereby rescinds Bulletins 25-10 and 25-11, effective June 1, 2026.
Despite this, the Department is aware that recovery efforts in some parts of the State
are still underway and that many property owners are actively repairing their properties.
To the extent these repairs are not finished, the property owner may have difficulty
securing new coverage. In addition, the Department acknowledges the unnecessary
stress and burden a property owner would experience if they had to obtain replacement
insurance coverage while still completing repairs.

Therefore, through the issuance of this Bulletin, the Department requests insurers
continue to provide additional time to impacted Missourians before instituting (or
initiating) cancellation or non-renewal of policies where the property owner is making
good-faith efforts to complete repairs to the damaged property. Delays in repairs may be
caused by issues with contractors or supplies, or unresolved aspects of the claim.
For those insurers who comply with this request to continue coverage for impacted
Missourians, the Department extends a regulatory safe harbor and states it will not take
any regulatory action against an insurer for making case exceptions to their filed
underwriting standards and policies.
If, for reasons such as administrative efficiency, an insurer extends the application of
this policy on a broader basis, the Department would support such measures and would
likewise extend a regulatory safe harbor to those insurers.

Regardless of what actions the insurer takes, the Department reminds insurers to
ensure their underwriting files contain all necessary information and documentation to
support their ultimate decision and actions.
This Bulletin will remain in effect until otherwise rescinded.

Any questions or comments regarding this Bulletin should be directed to the Market
Regulation Division by email at marketconduct@insurance.mo.gov.

                                            ###


26-08 - Conduent Cybersecurity Breach, May 5, 2026

DEPARTMENT OF COMMERCE & INSURANCE
                         P.O. Box 690 , Jefferson C ity. Mo, 65102-0690

       INSURANCE BULLETIN 26-08

       Conduent Cybersecurity Breach

       Issued: May 5, 2026

The following Bulletin is issued by the Missouri Department of Commerce and
Insurance ("Department'? to inform and educate the reader on the specified
issue. It does not have the force and effect of law, is not an evaluation of any
specific facts or circumstances, and is not binding on the Department. See
section 374.015, RSMo.

To:     All entities regulated by the Department
                                                        I
                                                            V1 ' Ii _     /'I

From: Angela L. Nelson, Director        ~ 17( / I ~
Re:     Addendum - Conduent Cybersecurity Breach

This bulletin is issued as a follow-up to Insurance Bulletin 26-05 to provide additional
information to insurers and other entities regulated by the Missouri Department of
Commerce and Insurance ("Department") regarding the Conduent cybersecurity breach.
This bulletin also requests information from insurers and other entities regulated by the
Department.
Background

Conduent Business Services, LLC (“Conduent”) provides document processing
services, including receiving insurance claim forms, payment integrity services, and
other back-office support services to a variety of entities, including but not limited to
insurers.

According to media reports, on January 13, 2025, Conduent discovered that an
unauthorized third party had access to a portion of its network from October 21, 2024, to
January 13, 2025. The affected files contained names, addresses, social security
numbers, and medical records. Reports vary on the impact of the breach, with some
estimating that potentially 25 million Americans or more were affected.

Since the issuance of Insurance Bulletin 26-05 on March 17, 2026, the Department has
been in direct contact with Conduent to better understand the Conduent cybersecurity
breach and its impact on Missouri insurance consumers, and to ensure that Missourians
receive the identity protection assistance they deserve.

To date, Conduent has been unwilling to provide the Department with the information
the Department needs to assess the impact of what is reportedly one of the largest
cybersecurity breaches in United States history.

As a result of Conduent’s lack of cooperation, the Department is reminding insurers and
other entities regulated by the Department to review Insurance Bulletin 26-05 and
ensure they have taken the steps outlined therein.

Actions Needed:

Because of Conduent’s failure to provide information, the Department asks that any
insurer or other entity regulated by the Department that utilized the services of
Conduent or any of its affiliates prior to or during the time period of the cybersecurity
breach, either directly or indirectly, contact the Department’s Market Conduct Section at
marketconduct@insurance.mo.gov.

The Department would greatly appreciate insurers or other entities also providing
information on the nature of services provided by Conduent or its affiliates. This
information will guide the Department’s response to the cybersecurity breach.

                                              2
The Department also reminds insurers and other regulated entities of their duties to
report cybersecurity breaches to the Director using the form available on the
Department’s website at https://apps.dci.mo.gov/forms/CybersecurityEventNotification,
and as further outlined in the resources below:

             Insurance Bulletin 26-01
             Insurance Bulletin 23-04
             Section 407.1500 RSMo
             The Insurance Data Security Act

Questions for the Department regarding an entity’s duties can be sent to
cyberbreach@insurance.mo.gov.

Questions relating to the Conduent cybersecurity breach may be directed to Conduent.
Conduent has a dedicated assistance line at 877-332-1658 (toll free), Monday-Friday,
from 9:00 a.m. to 9:00 p.m. Eastern Time, and may also be contacted at Attn: Data
Incident, 100 Campus Drive, Suite 200, Florham Park, New Jersey 07932.

Questions relating to the content of this bulletin may be directed to the Department’s
Market Conduct Section at marketconduct@insurance.mo.gov

                                           ###

                                            3


22-03 - Health Insurance Rate Filings - Filing Dates for Plan Year 2023, March 15, 2022

DEPARTMENT OF COMMERCE AND INSURANCE
                                               P.O. Box 690, Jefferson City, Mo. 65102-0690

                   INSURANCE BULLETIN 22-03
                   Health Insurance Rate Filings - Filing Dates for Plan Year 2023

                   Issued: March 15, 2022

          The following Bulletin is issued by the Missouri Department of Commerce and
          Insurance (“Department”) to inform and educate the reader on the specified issue. It
          does not have the force and effect of law, is not an evaluation of any specific facts or
          circumstances, shall not be considered a statement of general applicability and is not
          binding on the Department. See § 374.015, RSMo (2016).

          To:       Health carriers writing health insurance or health benefit plan coverage in Missouri

          From: Director Chlora Lindley-Myers

          Re:       Health Insurance Rate Filing Key Dates (2023 Plan Year)

          This Bulletin provides notice to health carriers of key filing dates for health benefit plans that will
          be offered during 2023, as required by §376.465, RSMo (2016)1, and 20 CSR 400-13.100. These
          dates are based on current federal guidance, and are subject to change.

          As of the date of issuance of this bulletin, Congress has not taken action to extend beyond calendar
          year 2022 the expanded eligibility for Advanced Premium Tax Credits enacted as part of the
          American Rescue Plan. The Department’s expectation for the 2023 plan year is that carriers will
          file ONE set of rates and outline their assumptions in the actuarial memorandum. The Department
          will not accept a rate filing with multiple rates for multiple contingencies for plan year 2023.

1
    All statutory references herein are to RSMo (2016) unless otherwise noted.
                                                                     1
For plan year 2023, the Department strongly encourages carriers in the individual market to assume
that Cost Sharing Reduction (CSR) payments will not be made by the federal government, and to
apply the CSR payment load only to Silver plans sold on the exchange. Furthermore, carriers are
strongly encouraged to include in their actuarial memorandum the amount of CSR load included in
the silver plan rates and the methodology for determining the load.

                          Summary of Filing Timeframes for Plan Year 2023

           Type of Plan                                    Filing Timeframe
 Single Risk Pool – Plans in      File between June 18, 2022 and June 22, 2022 to meet federal
 Individual and Small Group       and state guidelines.
 ACA markets
 Transitional                     File at least 60 days prior to use. Filings, which include finalized
                                  rates, that are submitted on or before August 17, 2022 will have
                                  their reviews prioritized.
                                  Filings submitted later than August 17 may have reviews
                                  extend beyond the intended implementation date.

 Grandfathered                    File at least 30 days prior to use.
 Student Health Plans             File at least 60 days prior to use.
 Other Health Benefit Plans       File at least 30 days prior to use.
 (Dental, Vision, etc.)

                                           #        #       #

For additional detail regarding the timeframes in the chart above, please see the following sections.

Applicability
The purpose of this Bulletin is to announce rate filing timeframes for plan types subject to a
determination of “reasonableness” pursuant to §376.465.7. For ease, this Bulletin will refer to the
following plans as “Subsection 7 Plans”:

           “Health benefit plans” as defined in §376.465 (excluding plans sold in the large
            employer group market);
           Individual and small employer group plans subject to the requirements of the single risk
            pool;
           Student health plans; and
           Transitional plans.

Section 376.465 specifies the timeframes applicable to rate filings for all other health benefit plans
including, but not limited to, grandfathered plans and excepted benefit plans.

                                                   2
File Rates for Individual and Small Group ACA Plans No Later than June 22, 2022
The Centers for Medicare and Medicaid Services (CMS), Center for Consumer Information and
Insurance Oversight (CCIIO) designated Missouri as an “Effective Rate Review” state in 2017. To
retain that status, the Department must ensure rate filings meet federal guidelines. This Bulletin
serves to indicate that the Department intends to follow federal filing and posting guidelines to the
extent possible under Missouri law.

For Plan Year 2023, proposed rates for Individual and Small Group ACA plans must be submitted to
the Department no earlier than June 18, 2022, and no later than June 22, 2022.

Federal law exempts student health plans from the filing deadlines applicable to single risk pool
plans. Likewise, federal guidance indicates that transitional plans have different deadlines than
single risk pool plans. However, in order to comply with Missouri law, rates for student health plans
and transitional plans should be filed with the Department at least 60 days prior to the proposed
effective date.

Post Proposed Rates for Individual and Small Group ACA Plans – July 27, 2022
Current federal guidelines require “Effective Rate Review” states to post proposed rates for single
risk pool plans no later than July 27, 2022. The Department does not intend to post proposed rates
earlier than this date.

Optional Quarterly Rate Filings for the Small Group Market
Current federal law permits single risk pool plans in the small group market to adjust rates as often
as quarterly. As Missouri law does not limit the frequency of rate filings, health carriers may submit
quarterly rate filings for small group market plans.

         2023 Plans: Health carriers should submit rate filings by June 22, 2022. Rate filings for
          subsequent quarters should be filed at least 60 days prior to the proposed effective date, as
          required by §376.465.

Transitional Plan Rate Filings
Missouri law doesn’t differentiate between transitional plans and other Subsection 7 plans.
Therefore, transitional plan rates must be filed at least 60 days prior to implementation, and are
subject to the same standards of review as other Subsection 7 plans. However, while current federal
guidance for transitional health plans only requires rate submissions where the proposed rate
increase exceeds the federally identified rate review threshold, under Missouri law all transitional
plan rate changes must be filed with the Department, regardless of the magnitude or direction of the
rate change.

Please note, for transitional plan rate changes that are less than the federal threshold, the Department
will not require companies to also file concurrently with CMS per 20 CSR 400-13.100(8).

For Additional Rate Filing Guidance
General Instructions are available via the System for Electronic Rate and Form Filing (SERFF) for
Missouri. Additional filing guidelines will be posted on the Department’s website and updated as
necessary.

                                                   3
Rate Filings for other Health Benefit Plans
For filing requirements applicable to grandfathered and excepted benefit plans that are not
Subsection 7 plans, please see §376.465. For dental plans that a health carrier or licensed pre-paid
dental plan intends to make available on the exchange, rates must be filed in accordance with
§376.465, or thirty (30) days prior to the intended effective date.

Any questions or comments regarding this Bulletin should be directed to Camille Anderson-Weddle
at 573-522-3311 or Camille.Anderson-Weddle@insurance.mo.gov.

                                                  4


22-02 - Updated Disaster Contact Information, February 18, 2022

INSURANCE BULLETIN 22-02
          Updated Disaster Contact Information

          Issued: February 18th, 2022

The following Bulletin is issued by the Missouri Department of Commerce and Insurance
(“Department”) to inform and educate the reader on the specified issue. It does not have the
force and effect of law, is not an evaluation of any specific facts or circumstances, and is not
binding on the Department. See section 374.015, RSMo.

To:              All insurers issuing policies covering real or personal property in Missouri

From:            Chlora-Lindley Myers, Director

Re:              Updated Disaster Contact Information

In anticipation of the upcoming spring storm season, and to ensure prompt and efficient
communications with the insurance industry following a disaster, the DCI requests each insurer
insuring real or personal property in the state to provide the following contact information to the
DCI:

      •   Primary regulatory contact: This contact should be available to directly communicate
          with the Director and senior DCI leadership following a disaster within the state. These
          would be high-level communications about the DCI’s response efforts, the company’s
          response efforts, logistic issues and other urgent regulatory matters following a disaster.
   •   Secondary regulatory contact: This secondary contact should be able to discuss non-
       urgent regulatory issues with DCI staff as well as participate in industry conference calls
       and meetings regarding disaster response matters.

   •   Communications contact: This contact should be available to discuss inquiries received
       from press outlets and to coordinate joint communication and consumer outreach efforts.

For each insurer contact type identified above, the DCI is requesting contact information (name,
title telephone numbers, email address) be submitted on the accompanying Excel spreadsheet
form. Responses can be emailed to CompanyContacts@insurance.mo.gov

Where there are multiple insurers within a larger group, a single response may be submitted if
the individuals identified for the larger group can speak to the issues identified above for each
insurer within the group.

Any questions or comments regarding this Bulletin should be directed to the Market Conduct
Examination Section by telephone at (573)751-2430 or you may utilize the email provided
above.


22-01 - Termination and Placement of Insurance Coverages, February 2, 2022

INSURANCE BULLETIN 22-01
Termination and Placement of Insurance Coverages

Issued: February 2, 2022

      The following Bulletin is issued by the Missouri Department of Commerce and Insurance
      (“Department”) to inform and educate the reader on the specified issue. It does not have the
      force and effect of law, is not an evaluation of any specific facts or circumstances, and is not
      binding on the Department. See section 374.015, RSMo.

To:         All insurers writing insurance coverages in the State of Missouri

From:       Chlora Lindley-Myers, Director

Re:         Termination and Placement of Insurance Coverages

This Bulletin is issued to provide information regarding the practice of replacing insurance coverage
terminated by one carrier (“terminating carrier”) with insurance coverage provided by a different carrier
(“new carrier”). There appears to be uncertainty in the marketplace regarding the consumer consent required
to be obtained by the new carrier to issue and bind coverage after coverage is discontinued by the
terminating carrier. Specifically, the question has arisen whether a new carrier may collect data from the
terminating carrier or its producers, without an application from the consumer, and simply issue new
policies or new certificates of coverage to those consumers whose policies or certificates are being non-
renewed by the terminating carrier. This bulletin only applies where an offer of coverage to consumers is
made by a new carrier who is unaffiliated with the terminating carrier.

A contract of insurance, like other contracts, requires a meeting of the minds of the parties to the contract.
See Byrne v. Prudential Ins. Co. of America, 88 S.W.2d 344 (Mo. 1935); Helmkamp v. American Family
Mutual Insurance Company, 407 S.W.2d 559 (MO. App. S.D. 1966). Where the consumer has not
submitted an application for coverage, some other affirmative consent is required from the consumer to
establish a meeting of the minds, and for the new carrier to bind coverage or issue a policy or certificate to
a consumer. A policy or certificate issued to a consumer without application or affirmative consent is not a
valid contract.
The provisions of Section 375.936.6 RSMo regarding misrepresentations of insurance policies are
implicated where an insurer or producer enrolls a consumer in insurance coverage or issues an insurance
policy or certificate without the affirmative consent of the consumer. In addition, 15 CSR 60-8.060 prohibits
of the use of negative option plans. The use of an opt-out or negative option methodology is not sufficient
to show affirmative consent, nor is the payment of premium, in and of itself, sufficient to show affirmative
consent. Affirmative consent, in this instance, means an affirmative statement, either verbally or in writing,
that indicates acceptance of the offer of coverage.

Any questions or comments regarding this Bulletin should be directed to Teresa Kroll at
marketconduct@insurance.mo.gov

                                                     ###


26-07 - Scam Alert: Phishing Email Campaign Targeting Producers and Other Users of the National Insurance Producer Registry (NIPR) Licensing Platform, April 9, 2026

OF COMMERCE
         DEPARTMENT         AND INSURANCE
                           P.O. Box 690, Jefferson City, Mo. 65102-0690

        INSURANCE BULLETIN 26-07
        Scam Alert: Phishing Email Campaign Targeting Producers
        and Other Users of the National Insurance Producer Registry
        (NIPR) Licensing Platform

        Issued: April 9, 2026

The following Bulletin is issued by the Missouri Department of Commerce
and Insurance ("Department") to inform and educate the reader on the
specified issue. It does not have the force and effect of law, is not an
evaluation of any specific facts or circumstances, shall not be considered a
statement of general applicability and is not binding on the Department.
See § 37 4.015, RS Mo (2016).

To:      All users of the National Insurance Producer Registry (NIPR) licensing platform,

From:    ::~:~:~
               .i::::~D:::::er
Re:      Phishing Scam Targeting NIPR Users

The Director of the Department of Commerce and Insurance issues this bulletin to alert
insurance producers and other users of the National Insurance Producer Registry
(NIPR) to an active phishing email campaign targeting NIPR users.

The phishing email campaign sends fraudulent emails to NIPR users that reference
past-due invoices and may appear to originate from familiar or trusted domains,
including @nipr.com, @naic.org, or @stripe. The emails falsely claim to be from
NIPR and request payment. These messages are fraudulent and were not sent from an
official NIPR email address or account.

Any unexpected or unsolicited invoice should be treated as suspicious:

   •   If a producer or other NIPR user receives an unexpected invoice email claiming
       to be from NIPR, stop immediately.

   •   Do not open attachments, click links, or submit payment in response to
       suspicious or unexpected invoice emails.

   •   If there is any doubt about the legitimacy of an invoice or email, contact
       niprbillingdept@nipr.com before responding or taking further action

For more information, insurance producers and other NIPR users are encouraged to
visit NIPR’s phishing information page. This page includes helpful tips for identifying
fraudulent emails, including unmasking vanity/fake email domains, looking for generic
greetings (e.g., “Dear Customer”), and examining the tone and grammar of emails for
signs of phishing.

NIPR's and NAIC’s cybersecurity teams are actively investigating and monitoring this
phishing activity.

Questions regarding this Bulletin can be directed to the Licensing Section at 573-751-
3518 or licensing@insurance.mo.gov.

                                          ###

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