# KY Insurance Advisory Opinion 1999-01: Conversion Plans As Health Benefits Plans

> Kentucky · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-01

## Section

- **Citation:** KY Insurance Advisory Opinion 1999-01
- **Heading:** Conversion Plans As Health Benefits Plans
- **Jurisdiction:** Kentucky
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** Kentucky Department of Insurance Bulletins and Advisory Opinions / Conversion Plans As Health Benefits Plans

## Text

Conversion Plans as Health Benefits Plans
The following Advisory Opinion is to advise the reader of the current position of the Kentucky
Department of Insurance (“the Department”) on the specified issue. The Advisory Opinion is not legally
binding on either the Department or the reader.

Kentucky Department of Insurance
Advisory Opinion 99-01

In re: Conversion Plans as Health Benefit Plans

RELEVANT FACTS AND STATUTES: A recent question has arisen concerning conversion plans discussed in
KRS 304.18-110. The question is are conversion plans considered health benefit plans pursuant to House
Bill 315 Section 1(17)?

DEPARTMENT’S POSITION: KRS 304.18-110(5) confers on group members the right to conversion
coverage upon termination of their group coverage.

House Bill 315 Section 1(17) defines "health benefit plan." Included in that definition are HMO contracts,
coverage through provider-sponsored integrated delivery networks, and coverage through insurance
companies. Certain forms of coverage are specifically excluded from the definition of health benefit
plans. Policies specifically excluded include, but are not limited to, credit policies, dental policies, long-
term care policies, and specified disease policies.

KRS 304.18-110, providing for conversion policies, was in effect before House bill 315 was enacted into
law. If the General Assembly wanted to exclude conversion policies from the definition health benefit
plans it would have included conversion policies in the list of specifically excluded coverages. Since
conversion policies are not specifically excluded, they are included in the definition of health benefit
plans.

In as much as conversion policies are health benefit plans, they will need to be filed in conformity with
House Bill 315. Carriers must notify the Department within thirty (30) days from the effective date of
this Advisory Opinion as to how they are complying with the conversion requirements of KRS 304.18-
110, pursuant to this Advisory Opinion
ded in the definition of health benefit
plans.

In as much as conversion policies are health benefit plans, they will need to be filed in conformity with
House Bill 315. Carriers must notify the Department within thirty (30) days from the effective date of
this Advisory Opinion as to how they are complying with the conversion requirements of KRS 304.18-
110, pursuant to this Advisory Opinion. Carriers needing to file their conversion policy forms and rates
with the Department must do so within sixty (60) days from the date of their notice. Offering a
conversion policy does not constitute doing business in the individual market. Therefore, a carrier is not
required to offer the standard plan as a conversion option.

Any questions may be directed to Shaun T. Orme, Counsel for the Department.

_____________________

George Nichols III

Commissioner

Date: 1/20/99

_______________

## Nearby sections

- [KY Insurance Advisory Opinion 1998-01 The Issuance And Renewal Of Health Benefit Plans Under 98 RS HB 315/En](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1998-01.md)
- [KY Insurance Advisory Opinion 1998-02 Hospice Care Coverage Under Health Benefit Plans](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1998-02.md)
- [KY Insurance Advisory Opinion 1998-03 Health Care Discount Programs](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1998-03.md)
- [KY Insurance Advisory Opinion 1998-04 Participation Requirements For Groups](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1998-04.md)
- [KY Insurance Advisory Opinion 1998-05 Damages For Motor Vehicle Loss Of Use And Settlement Of Claims For Motor Vehicles](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1998-05.md)
- [KY Insurance Advisory Opinion 1999-01 Conversion Plans As Health Benefits Plans](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-01.md)
- [KY Insurance Advisory Opinion 1999-02 Use Of Fee Schedules For Payment Of Medical Expenses In Basic And Added Reparation Benefits Coverage](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-02.md)
- [KY Insurance Advisory Opinion 1999-03 Experience-Information Reports Of Insurers](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-03.md)
- [KY Insurance Advisory Opinion 1999-05 Group Claim Experience](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-05.md)
- [KY Insurance Advisory Opinion 1999-06 Claims Practice](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-06.md)
- [KY Insurance Advisory Opinion 1999-07 Dual Rates For Medicare Supplement Policies](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-07.md)
- [KY Insurance Advisory Opinion 1999-08 Any Willing Provider Law](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-08.md)
- [KY Insurance Advisory Opinion 1999-12 Bulletin 98-2 Personal Lines Property Insurance For Earthquake Damages](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-12.md)
- [KY Insurance Advisory Opinion 1999-13 Waiver Of Our Right To Recover From Others Endorsements (Ncci Form Wc 00 01 13)](https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-13.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/KY_INS_AO_1999-01. Check the current official text before relying on it. Not legal advice.
