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    v1.0.28
    OpenPayerPolicy UpdatesAdministrative/Operational PolicySouth Carolina DOI filing deadline extensions | Op…
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    CurrentSouth Carolina Department of InsurancePolicy 2020-05

    Complying with Regulatory Requirements During the 2019 Novel Coronavirus Public Health Emergency

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    Bulletin advising South Carolina-licensed insurers, HMOs, and captive insurers of temporary extensions and flexible submission procedures for specific regulatory filings and examinations during the COVID-19 public health emergency.

    Policy Summary
    PayerSouth Carolina Department of Insurance
    PolicyComplying with Regulatory Requirements During the 2019 Novel Coronavirus Public Health Emergency
    Policy CodePolicy 2020-05
    Change TypeOperational guidance — temporary deadline extensions
    Effective DateApr 24, 2020
    Next Review DateN/A
    Key ActionInsurers must submit a notification for late filing to receive additional time.
    SourceLink
    POLICY UPDATE CHANGES

    No material clinical or coverage changes in this revision.

    30-day30-day extensions
    60-day60-day extensions
    June 15, 2020NAIC quarterly deadline
    60 daysHard copy submission window

    OpenPayer is powered by Trek Health's payer performance platform. Trek continuously ingests, validates, and normalizes Transparency in Coverage data alongside payer policies and other commercial payer data to create a structured payer intelligence foundation. OpenPayer uses this foundation to deliver personalized search results, dynamically generated policy pages, and tailored policy monitoring based on each user's payers, specialties, billing codes, and areas of interest. The same intelligence powers broader payer performance workflows, including reimbursement benchmarking, contract evaluation, payer negotiations, and financial decision-making.

    Eligibility and Operational Criteria

    Filing extension criteria

    Listed filings are eligible for specified deadline extensions as indicated below.

    30-day extensions

    • Combined Annual Statement Filing (Property) — original deadline May 1, 2020; revised deadline June 1, 2020.
    • Combined Insurance Expense Exhibit (Property) — original deadline May 1, 2020; revised deadline June 1, 2020.
    • Accountant's Letter of Qualifications (Property, Life/Fraternal, Health, Title) — original deadline June 1, 2020; revised deadline July 1, 2020.
    • Captive Insurance Company Annual Audit and Annual Certification of Loss Reserves and Loss Expense Reserves (excluding risk) — original deadline June 30, 2020; revised deadline July 30, 2020.
    • Captive Insurance Company Annual Report and supplemental filings (excluding risk retention groups) — original deadline July 1, 2020; revised deadline August 1, 2020.
    • PBR Exemption filing due to state 7/1 and to NAIC 8/15 (Life/Fraternal) — original deadline August 15, 2020; revised deadline September 15, 2020.

    60-day extensions

    • 2020 Actuarial Memorandum Required by Actuarial Guideline XXXVIII 8D (Life/Fraternal) — submitted only to insurer's state of domicile; original deadline April 30, 2020; revised deadline June 30, 2020.
    • Audited Financial Report (Property, Life/Fraternal, Health, Title) — original deadline June 1, 2020; revised deadline August 1, 2020.
    • Communication of Internal Control Related Matters Noted in Audit (Property, Life/Fraternal, Health, Title) — original deadline August 1, 2020; revised deadline October 1, 2020.
    • Corporate Governance Annual Disclosure — original deadline June 1, 2020; revised deadline August 1, 2020.
    • Management's Report of Internal Control Over Financial Reporting (Property, Life/Fraternal, Health, Title) — submitted only to insurer's state of domicile; original deadline August 1, 2020; revised deadline October 1, 2020.

    NAIC quarterly and related filings

    • Quarterly Statement Filing as of March 31, 2020 (Property, Life/Fraternal, Health, Title) — original deadline May 15, 2020; revised deadline June 15, 2020.
    • Trusteed Surplus Statement - Quarter Ending March 31, 2020 (Property, Life/Fraternal) — original deadline May 15, 2020; revised deadline June 15, 2020.
    • Supplement A to Schedule T - Quarter Ending March 31, 2020 (Property) — original deadline May 15, 2020; revised deadline June 15, 2020.
    • Medicare Part D Coverage Supplement - Quarter Ending March 31, 2020 (Property, Life/Fraternal, Health) — original deadline May 15, 2020; revised deadline June 15, 2020.
    • Other listed NAIC electronic filings (e.g., Merger/history quarterly form, Reasonableness/Consistency of Assumptions Certifications, Director and Officer Insurance Coverage Supplement) — original deadlines May 15, 2020 (or June 1 for CQA); revised deadlines June 15, 2020 (or July 1 for the Comprehensive Quarterly Analysis).
    Entities should note the specific original and revised deadlines above for each filing to ensure compliance with the temporary extensions set by the Department.

    Electronic filings and signatures

    Electronic filings and signatures during the State of Emergency

    The Department will accept an electronic signature on the jurat or other pages in lieu of a wet ink signature provided the submitter has complied with the South Carolina Uniform Electronic Signatures Act (SCUETA).
    The Department will accept and encourages companies to file electronic copies of filings during the State of Emergency; companies must retain the original filing and a list of all filings made electronically.
    Once the State of Emergency has been lifted, companies will have 60 days to submit hard copies of filings that were filed electronically during the emergency.

    Examination procedures

    On-site examinations

    The Department can perform full-scope examinations electronically and intends to comply with government directives regarding public gatherings; it will not conduct on-site examination work that is contrary to public health directives.
    To facilitate electronic examinations, the Department may request additional information in electronic form and expects independent auditors to take a similar position.
    Insurers currently scheduled for an upcoming examination are encouraged to proactively file the audited financial report and not wait until the extended deadline.

    Notifications and Required Actions by Insurers

    Documentation Required

    Submit notification to receive extended filing deadlines

    To receive the additional time for the temporary filing deadline extensions, insurers must submit a notification of intent to file (notification for late filing) for their company. The Department may still require an earlier filing based on the company’s financial condition and unique circumstances; company-specific extension requests (e.g., alternate fiscal year-ends) require a separate extension request and prior approval.

    • Submit an electronic notification of intent to file the specific filing(s) by the revised deadlines or send an extension request to fnclmail@doi.sc.gov or captivemail@doi.sc.gov, as applicable.
    • Be aware the Department reserves the right to require earlier filing depending on the company’s financial condition and circumstances.
    • Company-specific deadlines not listed in the bulletin require a separate extension request and prior approval.

    Key Definitions

    Electronic signature (SCUETA) and related requirements
    Accepted in lieu of wet inkElectronic signatures on jurats or other pages will be accepted if the submitter complies with the South Carolina Uniform Electronic Signatures Act (SCUETA).
    Notarization requirement under SCUETAA law requiring a signature or record to be notarized, acknowledged, verified, or made under oath is satisfied if the electronic signature of the person authorized to perform those acts, together with all other required information, is attached to or logically associated with the record.
    Retention of original filingsCompanies must keep the original filing even when filing electronically during the State of Emergency.
    Inventory of electronic filingsCompanies are expected to maintain a list of all filings submitted electronically in lieu of hard copy filings.
    Deadline to submit hard copies after State of EmergencyOnce the State of Emergency is lifted, companies will have 60 days to submit hard copies of filings.
    Policy Summary
    PayerSouth Carolina Department of Insurance
    PolicyComplying with Regulatory Requirements During the 2019 Novel Coronavirus Public Health Emergency
    Policy CodePolicy 2020-05
    Change TypeOperational guidance — temporary deadline extensions
    Effective DateApr 24, 2020
    Next Review DateN/A
    Key ActionInsurers must submit a notification for late filing to receive additional time.
    SourceLink
    On This Page
    Eligibility and Operational CriteriaNotifications and Required Actions by InsurersKey Definitions
    Annual renewal date for Reinsurance Intermediaries — original deadline June 1, 2020; revised deadline August 1, 2020 (extended to correspond with Audited Financial Reports extension).