Non-Grandfathered Transitional Policy Information Bulletin

Commissioner of Securities and Insurance Troy Downing Commissioner INFORMATIONAL BULLETIN Office of the Montana State Auditor To: Health Insurers providing Non-Grandfathered/Transitional Coverage in the Small Group and/or Individual Market From: Troy Downing /-h. missioner of Securities and Insurance Re: Bulletin from the Centers for Medicare & Medicaid Services' - Insurance Standards Bulletin Series -IN FORMATION - Extension of Limited Non-Enforcement Policy through 2022 Date: February 23, 2021 NON-GRANDFATHERED/TRANSITIONAL POLICY On January 19, 2021, the Centers for Medicare & Medicaid Services ("CMS") issued a Bulletin extending its non-enforcement policy regarding non-grandfathered transitional policies that do not meet certain ACA market reform requirements ("Bulletin"). CMS will not act against these plans for non-compliance with the specified market reforms for policy years beginning on or before October 1, 2022, provided that all such coverage comes into compliance by January 1, 2023. The Montana State Auditor, Commissioner of Securities and Insurance ("CSI") has adopted the CMS transitional policy for individual and small group policies through 2022. Health insurance issuers must comply with the requirements and terms in the Bulletin. See the Bulletin at: https://www.cms.gov/files/document/extension-limited-non-enforcement-policythrough-calendar-year-2022.pdf The Bulletin will be posted on the CSI website at www.csimt.gov and placed in the System for Electronic Rates & Forms Filing (SERFF).