Extension of Transitional Plans through December 31, 2018

State of Idaho

DEPARTMENT OF INSURANCE

C.L. “BUTCH” OTTER

Governor

700 West State Street, 3rd Floor

P.O. Box 83720

Boise, Idaho 83720-0043

Phone (208)334-4250

Fax (208)334-4398

Website: http://www.doi.idaho.gov

DEAN L. CAMERON

Director

1

BULLETIN NO. 17-01

DATE: March 8, 2017

TO: Disability/Health Insurance Carriers in Group or Individual Markets

FROM: Dean L. Cameron, Director

SUBJECT: Extension of Transitional Plans through December 31, 2018

This bulletin to carriers in the employer and individual health insurance markets provides

guidance regarding the extension of non-grandfathered transitional plans (also known as

“grandmothered” plans) through December 31, 2018.

Bulletin No. 13-05 addressed carriers continuing to offer grandmothered individual and small

employer policies in existence on October 1, 2013 at their 2014 renewal. Subsequent federal

guidance allowed for further extensions of these plans, which the Department chose to allow.

Bulletin No. 16-03 set forth the requirements for extension of grandmothered plans through

December 31, 2017. New CMS guidance, released February 23, 2017, allows states the option of

extending the grandmothered plans for an additional year, through December 31, 2018.

Grandmothered plans in the Idaho individual and small group markets will be permitted to

extend through December 31, 2018. Carriers must continue to abide by the requirements of

Bulletin No. 16-03 for all renewals of grandmothered plans through December 31, 2017. This

will result in all grandmothered plans being on a calendar year renewal schedule; policyholders

of those plans must then be offered a renewal for the 12 month period beginning January 1,

2018

ts will be permitted to

extend through December 31, 2018. Carriers must continue to abide by the requirements of

Bulletin No. 16-03 for all renewals of grandmothered plans through December 31, 2017. This

will result in all grandmothered plans being on a calendar year renewal schedule; policyholders

of those plans must then be offered a renewal for the 12 month period beginning January 1,

2018.

The grandmothered plans must continue to comply with the following ACA provisions:



Elimination of annual dollar limits on EHB as defined by the Idaho benchmark plan, to

the extent the grandmothered plans cover EHB



No pre-existing condition exclusion (small groups)



Waiting periods not to exceed 90 days (small groups)



Mental health parity rules (individual plans upon renewal July 1, 2014 or later; not

applicable to small group plans)

Carriers are required to provide a notice at renewal which informs the individual or small

employer of the option to renew the existing coverage or to enroll in a new plan on or off Your

Health Idaho, and also includes the information that some ACA market reforms are not included

in their current plans. The notice, available on the Department website, must be used without

modification, and must be mailed without any other materials except for a cover letter, which

may include the renewal premium.

If you have questions concerning this bulletin, please contact Kathy McGill or Wes Trexler at the

Department of Insurance.