IA Bulletin 22-01
CMS allows extension for transitional policies indefinitely
KIM REYNOLDS
DOUG OMMEN
GOVERNOR
COMMISSIONER OF INSURANCE
ADAM GREGG
LT. GOVERNOR
1963 BELL AVENUE / SUITE 100 / DES MOINES, IOWA 50315-1000
Telephone 515-654-6600 / Facsimile 515-654-6500 / https://iid.iowa.gov
Bulletin 22-01
To: All Health Insurers Writing Business in the State of Iowa
From: Doug Ommen, Iowa Insurance Commissioner
RE: CMS allows extension for transitional policies indefinitely
Date: April 13, 2022
The purpose of Bulletin 22-01 is to provide guidance regarding the extension of transitional policies in the
State of Iowa. The Centers for Medicare and Medicaid Services (“CMS”) announced on March 23, 2022,
that health insurers will be allowed to continue transitional policies for policy years beginning after October
1, 2022, and will remain in effect until CMS announces that all such coverage must come into compliance
with the specified requirements.1
The Iowa Insurance Division (“IID”) will enact the CMS guidance and will also allow transitional policies
to remain in effect indefinitely. The IID appreciates federal authorities providing this state flexibility as they
have done every year since 2014.
Transitional policies provide access to healthcare coverage that is likely otherwise unaffordable. Currently,
58,295 Iowans have transitional policies in the individual and group markets. Year after year, Iowans have
had the opportunity to enroll in ACA plans but many choose to stay in transitional plans to avoid the very
high ACA rates, especially those in the individual market.
The structural flaws within the text of federal law make ACA plans unappealing to many younger, healthier
Iowans. Iowa intends to permit viable health insurance options for those who have been priced out of ACA
plans and appreciates CMS listening to input from Iowa2 to make the continuation of transitional plans
available for the foreseeable future. Iowa, once again, calls on the federal government to permit additional
flexibility to make changes that would make the ACA plans more attractive to younger, healthier Iowans.
1 See: https://www.cms.gov/files/document/extension-limited-non-enforcement-policy-through-calendaryear-2023-and-later-benefit-years.pdf
2 https://www.grassley.senate.gov/news/news-releases/grassley-ernst-press-cms-to-protect-high-qualityaffordable-health-insurance-for-65000-iowans