CurrentConnecticut Insurance DepartmentPolicy HC-90-21

Filing Requirements for Individual and Small Employer Group Health Insurance Policies Subject to the Affordable Care Act

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Governs form, rate, essential health benefit, network, formulary, and related filing requirements for non-grandfathered individual and small employer group health plans issued in Connecticut, both inside and outside Access Health CT.

Policy Summary

PayerConnecticut Insurance Department

PolicyFiling Requirements for Individual and Small Employer Group Health Insurance Policies Subject to the Affordable Care Act

Policy CodePolicy N/A

Change TypeNo material change

Effective DateN/A

Next Review DateN/A

Key ActionSubmit individual and small-group form and rate filings no later than July 2, 2021.

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

2Market segments covered

Jan 1, 2022Plan year begins

Jul 2, 2021Filing deadline

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CurrentConnecticut Insurance DepartmentPolicy HC-90-21

Filing Requirements for Individual and Small Employer Group Health Insurance Policies Subject to the Affordable Care Act

Customize your policy alerts

Sign up for Connecticut Insurance Department Policy HC-90-21 alerts

Get alerted when Policy HC-90-21 changes without checking for updates manually.

Monitor payer policy activity

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Policy Summary

PayerConnecticut Insurance Department

PolicyFiling Requirements for Individual and Small Employer Group Health Insurance Policies Subject to the Affordable Care Act

Policy CodePolicy N/A

Change TypeNo material change

Effective DateN/A

Next Review DateN/A

Key ActionSubmit individual and small-group form and rate filings no later than July 2, 2021.

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

2Market segments covered

Jan 1, 2022Plan year begins

Jul 2, 2021Filing deadline

Connecticut rating areas

All plansPlans requiring essential health benefits

Applicability and Filing Requirements

Essential Health Benefit Applicability

All individual and small employer group plans, whether offered inside or outside the exchange, must provide coverage for the essential health benefits.

ALL of the following

Plans in the individual market must provide coverage for the essential health benefits.
Plans in the small employer group market must provide coverage for the essential health benefits.
The requirement applies to plans offered both inside and outside of the exchange.
Information regarding the selected benchmark plan is available through Information on Essential Benefits (EHB) Benchmark Plans.

Form Filing Requirements

Connecticut Insurance Department (CID) form filing requirements apply to fully ACA-compliant individual and small group policies and certificates issued on or after January 1, 2014, whether offered in or out of the exchange.

ALL of the following

For the initial filing of each fully ACA-compliant individual and small group policy or certificate, file the complete contract.
Subsequent changes to approved policies or certificates may be filed as endorsements or amendatory riders.
Include a red-lined version in the filing submission where appropriate, and ensure the cover letter clearly identifies the types of changes being made.
Submit all form filings for individual and small group plans offered on or off the exchange no later than July 2, 2021.
Plans that are not approved before open enrollment are subject to a continual open enrollment period.
Exchange filings may receive priority to meet required federal deadlines; otherwise, filings are reviewed in the order received.

Rate Filing and Approval Requirements

Rate filings for individual and small group plans must satisfy Connecticut submission, approval, rating-factor, and plan-maintenance requirements.

ALL of the following

Make rate filings in accordance with Bulletin HC 81-21 regarding rate filing submission requirements, Bulletin HC-88 regarding association business when applicable, and Bulletin HC 106 regarding small group rate filings.
Submit rate filings no later than July 2, 2021 for all individual and small group plans to be offered beginning January 1, 2022, including plans offered on or off the exchange.
After July 2, 2021, no changes will be accepted unless specifically requested by the Insurance Department.
If an error is identified, the carrier may submit a communication in the SERFF filing describing the error and where it is located; a change in assumptions is not considered an error.

Rating Areas and Filing Timeline

Connecticut rating areas

Number of rating areas8

BasisCounty-based

Markets coveredIndividual and small group

StateConnecticut

Form and rate filing deadline

DeadlineJuly 2, 2021

Applicable filingsIndividual and small group form and rate filings

Carrier Filing and Compliance Actions

Documentation Required

Submit Complete Initial Forms and Document Changes

File complete contracts for the initial filing of all fully ACA-compliant individual and small-group policies or certificates issued on or after January 1, 2014, whether offered on or off the exchange. Submit subsequent changes as endorsements or amendatory riders.

Include a red-lined version when appropriate.
Clearly identify the types of changes in the filing cover letter.

Documentation Required

Provide Redlines and Change Descriptions

Include red-lined versions when appropriate and clearly describe the types of changes being made in the filing cover letter.

Policy Summary

PayerConnecticut Insurance Department

PolicyFiling Requirements for Individual and Small Employer Group Health Insurance Policies Subject to the Affordable Care Act

Policy CodePolicy N/A

Change TypeNo material change

Effective DateN/A

Next Review DateN/A

Key ActionSubmit individual and small-group form and rate filings no later than July 2, 2021.

SourceLink

On This Page

Form filings may use variable language for plans offered inside and outside the exchange.

Include a detailed explanation of variability covering the full range of options the carrier plans to offer and any variations in contract language.

The form filing does not need to include certification or demonstration of compliance with the various metal tiers because the URRT and required rate-filing documentation must detail specific plan options and demonstrate adherence to the applicable actuarial values.

Include a cross-reference in the form filing to the HIOS identifier in the URRT so the form filing can be matched to the rate filing.

The cover letter must clearly identify which plans will be offered on the exchange.

A carrier participating on the exchange does not need to submit a separate filing for plans offered off exchange.

Exchange plans must be made available outside the exchange at the same premium rate, benefits, network, and administrative expense levels, consistent with ACA section 2702 and associated regulations.

Exchange plans need not be actively marketed outside the exchange, but must be made available when requested.

The schedule of benefits should generally follow the format available on SERFF.

Schedules for on-exchange filings must also comply with AHCT requirements.

Schedules may contain variable language, but pages should be limited to information required in the Department-provided format.

Use the Department's preferred certificate format, which is available on SERFF, to assist in expediting review.

Previously approved certificate language must be placed into the preferred format; changes to language other than formatting must be redlined.

If forms are not submitted in the preferred certificate format, cross-reference where each certificate section appears by page number.

Generally, policy form and rate filings are not approved until review of both submissions is complete.

Conditional approval may be provided for one submission subject to approval of both submissions.

Do not offer an unapproved rate or plan during an open enrollment period under any circumstances.

After rate filings are approved, carriers may not add or withdraw plans or products.

Comply with all requirements of 45 CFR §147.102 regarding allowable rating factors, except for geographic rating areas, and comply with Conn. Gen. Stat. §38a-567 for group rates and §38a-481 for individual rates.

Connecticut has established eight rating areas by county for both the individual and small group markets.

Post-deadline changesNot accepted unless specifically requested by the Insurance Department

Prior Authorization

Meet the Form Filing Deadline

Submit all individual and small-group form filings for plans offered on or off the exchange no later than July 2, 2021. Plans not approved before open enrollment are subject to a continual open enrollment period.

Exchange filings may receive priority to meet required federal deadlines; other filings are reviewed in the order received.

Unsupported block type: documentationเจassistant

Documentation Required

Cross-Reference HIOS Identifiers

Cross-reference the HIOS identifier included in the Uniform Rate Review Template so the form filing can be matched to the corresponding rate filing.

Billing Rule

Identify and Offer Exchange Plans Off Exchange

Clearly identify in the cover letter which plans will be offered on the exchange. Carriers participating on the exchange must make all exchange plans available outside the exchange at the same premium rate, benefits, network, and administrative expense levels.

A separate off-exchange filing is not required.
Plans need not be actively marketed, but must be made available when requested.

Documentation Required

Follow Required Schedule and Certificate Formats

Use the general SERFF schedule-of-benefits format, satisfy Access Health CT requirements for on-exchange filings, and use the Department’s preferred certificate format.

Limit schedule pages to information required in the Department’s format.
Redline any language changes other than formatting when converting previously approved language to the preferred certificate format.
If the preferred certificate format is not used, cross-reference each certificate section by page number.

Prior Authorization

Meet Rate Filing Deadline and Change Restrictions

Submit rate filings for all individual and small-group plans to be offered beginning January 1, 2022, whether on or off the exchange, no later than July 2, 2021. No changes will be accepted after that date unless specifically requested by the Insurance Department.

If an error is found, submit a SERFF communication identifying the error and where it appears in the filing.
A change in assumptions is not treated as an error and does not qualify for this exception.
Prepare filings in accordance with Bulletin HC 81-21, Bulletin HC-88 when applicable, and Bulletin HC 106 for small-group rates.

Denial Risk

Obtain Approval Before Offering Plans

Do not offer an unapproved rate or plan during an open enrollment period. Coordinate form and rate filings because approval generally requires review of both submissions, although conditional approval of one may be issued subject to approval of the other.

Unapproved plans and rates may not be offered under any circumstance during open enrollment.

Billing Rule

Maintain the Approved Plan Portfolio

After rate filings are approved, do not add or withdraw plans or products.

Documentation Required

Complete Annual Formulary and Network Surveys

Plans that utilize formularies or networks must submit responses to the Department’s annual formulary and network surveys.

Access the surveys on the Insurance Department website under “Forms and Applications.”
Follow Bulletins HC-113-19 and HC-117-21.

Billing Rule

Apply Statutory Copayment Maximums

Maximum copayment amounts are eliminated except where maximums are required by statute.

Refer to Insurance Department Bulletin HC-124 for statutory requirements.