ALL COMPANIES WRITING ACCIDENT AND HEALTH INSURANCE AND MANAGED CARE PLANS IN ILLINOIS : ILLINOIS FILING REQUIREMENTS FOR INDIVIDUAL AND SMALL GROUP HEALTH PLANS, ON AND OFF-MARKETPLACE (ON AND OFF-EXCHANGE) AND STAND-ALONE DENTAL PLANS

Springfield Office 320 W. Washington Street Springfield, Illinois 62767 (217) 782-4515 Chicago Office 122 S. Michigan Ave., 19th Floor Chicago, Illinois 60603 (312) 814-2420 Illinois Department of Insurance JB PRITZKER Governor ROBERT H. MURIEL Director MEMORANDUM TO: ALL COMPANIES WRITING ACCIDENT AND HEALTH INSURANCE AND MANAGED CARE PLANS IN ILLINOIS FROM: ROBERT H. MURIEL, DIRECTOR OF INSURANCE DATE: MAY 8, 2020 RE: COMPANY BULLETIN 2020-13 ILLINOIS FILING REQUIREMENTS FOR INDIVIDUAL AND SMALL GROUP HEALTH PLANS, ON AND OFF-MARKETPLACE (ON AND OFF-EXCHANGE) AND STAND- ALONE DENTAL PLANS The purpose of this Bulletin is to provide instructions to Issuers seeking certification or recertification of individual and small group plans and Stand-alone Dental Plans (SADP) offered on the Individual and Small Business Health Options Program (SHOP) Marketplace. This Bulletin also applies to those plans offered off the Marketplace (Off-Exchange) in the individual and small group markets for Plan Year 2021. Note: The issuer deadlines apply to ALL individual and small group health plans, and dental plans offered on and off the Marketplace. Activity Dates Plan and Rate Application and Review Process Deadline for Issuers to Submit Plan Data and Rate Filings to Illinois Through SERFF 5/27/2020 Illinois DOI First SERFF Data Transfer Deadline 6/17/2020 CMS Reviews Initial Qualified Health Plan (QHP) Applications 6/18/2020 – 8/12/2020 Illinois DOI Second SERFF Transfer Deadline 7/22/2020 Deadline for Issuers to Submit Service Area Petition Changes 8/11/2020 Illinois DOI Deadline to Provide Issuer Service Area Petition Changes to CMS 8/11/2020 Illinois Deadline for Issuers to Submit Changes to Plan Submissions 8/21/2020 Illinois Transparency in Coverage data submission deadline 8/21/2020 Illinois Deadline for Issuers to Submit Changes to Rates 8/21/2020 Illinois DOI Second SERFF Data Transfer Deadline 8/26/2020 CMS Sends Final Correction Notices to Issuers with Agreements for Signature and Plan Lists Confirmation 9/15/2020 Illinois DOI Sends CMS Final Plan Recommendations 9/15/2020 – 9/23/2020 Page 2 of 3 Issuers Send Signed Agreements, Confirmed Plan Lists and Final Plan Crosswalks to CMS 9/15/2020 – 9/23/2020 QHP Agreement/ Final Correction Limited Data Corrections Window (Outreach to Issuers with CMS or Illinois DOI Identified Data Errors; Issuers Submit Corrections; CMS Reviews and Finalizes Data for Open Enrollment) 9/17/2020 – 9/18/2020 Transparency in Coverage data resubmission deadline 9/18/2020 CMS Sends Certification Notices with Counter-Signed Agreements and Final Plan Lists to Issuers 10/5/2020 – 10/6/2020 Open Enrollment Begins 11/1/2020 Issuers are advised to consult federal regulations, 2021 Letter to Issuers, and state law in conjunction with this Bulletin to ensure full compliance. Helpful documents can be found on the Illinois Department of Insurance’s ACA Issuer Homepage. • All form filings must be submitted in the format of a complete insurance policy. The Department will not accept matrix insert page filings, riders, amendments, variable language or brackets. Approved filing will only be reopened upon request from CMS. NOTE: Summary of Benefits and Coverage may contain bracketed information per the federal template, and the cover page may include brackets for policyholder name, policy number, product name, effective date of policy and other identifying data. • Visit the CMS QHP Certification Website and complete the QHP Application checklist. • For 2021 plans, Illinois will require the crosswalk template to be uploaded to the binders. • Submit all checklists, templates and supporting documentation in SERFF. • Provide a red-lined version identifying the variations in plan benefit design from the plans submitted for the previous plan year for each form filing submitted for recertification. Red-lined versions must be submitted under the supporting documentation tab in the form filing in SERFF. • Associate all relevant filings in the SERFF binder including but not limited to form, rate, external review, and network adequacy filings. • Previously filed Network Adequacy filings may be associated in the binder if no substantive changes have been made to the network. • Remit the fee of $3,000.00 for certification of each new QHP and $1,500.00 for recertification for existing QHP plans via EFT in SERFF binder filings at the time of binder submission. • Service Area Exemption: Issuers that fail to offer coverage to an entire rating area must obtain an exception from the Department. (See QHP Service Area Exception Form) The Issuer must provide service area maps to show compliance with the service area requirement. • For Plans that will be discontinued or modified, Issuers must submit the appropriate letters or notifications pursuant to 215 ILCS 97/60. Issuers may be required to attach other checklists and/or supporting documentation templates, as indicated by the ACA Individual, Small Group, and Catastrophic Checklists. Maximum Annual Limitation on Cost Sharing for Plan Year 2021 Individual Coverage Family Coverage Health Plans $8,550 $17,100 SADPs $350 $700 Page 3 of 3 Exhibit 1: 2021 Health Plans Filing Requirements – Form and Binder Required Submission Via SERFF Federal Required Templates On/Off- Exchange Off- Exchange Location All Applicable templates/documents listed on the CMS Certification Checklist Yes No Binder Illinois Required Documents ACA Individual, Small Group, and Catastrophic Checklist Yes Yes Form filing ACA Individual and Small Group SADP Checklist Yes Yes Form filing Network Adequacy and Transparency Checklist (not applicable to SADPs) Yes Yes Network Adequacy Filing Mental Health Parity Supporting Documentation Template (does not include SADP) Yes Yes Form Filing Proposed Enrollment Template Yes Yes Binder External Review Checklist (Not applicable to SADPs) Yes Yes External Review Filing QHP Rates Guidance: • The Department will allow carriers to modify their individual and small group rate filings through July 29, 2020 to reflect updated assumptions for both COVID-19 and risk adjustment. Other types of changes or changes after this date will be allowed at the discretion of the Department. All documents which change will need to be resubmitted in redline format, in order to allow for a more efficient review. • Since July 1, 2019, it has been illegal in Illinois to sell tobacco products to individuals under 21 years of age. Accordingly, premium rates for consumers in this age group should not include a tobacco load. Exhibit 2: 2021 Health Plans Filing Requirements – Rates Required Submission via SERFF Federal Required Templates On-Exchange Off- Exchange Location QHP Rating Module Documents • Rates Table Template • Business Rules Template Yes Yes Rate filing & Binder Unified Rate Review Template Yes Yes Rate Filing & Binder Illinois Required Documents Health Premium Rate checklist Yes Yes Rate Filing & Binder Proposed Enrollment Template Yes No Rate Filing & Binder