MT CSI Advisory Memorandum of 2019-08-02
UPDATE to 2019 Requirements Health Plan Form and Rate Filings
# COMMISSIONER OF SECURITIES & INSURANCE
MATTHEW M. ROSENDALE, SR.
COMMISSIONER
OFFICE OF THE MONTANA
STATE AUDITOR
TO: HEALTH INSURERS INTENDING TO ISSUE OR RENEW INDIVIDUAL
MARKETPLACE HEALTH INSURANCE IN 2020
FROM: Matt M. Rosendale, Commissioner of Securities and Insurance
DATE: August 2, 2019
Matt M. Rosendale
The Montana State Auditor, Office of the Commissioner of Securities and Insurance (CSI)
provides this information regarding submission of rate filings for individual marketplace health
insurance coverage effective in 2020.
Pursuant to Mont. Code Ann. ยง 33-22-1322, the Commissioner, along with the Governor and the
Montana Reinsurance Association Board of Directors, jointly submitted an application for a
Section 1332 Waiver under the Patient Protection and Affordable Care Act (PPACA) to the
Centers for Medicare and Medicaid Services (CMS). If approved, Montana intends to use the
waiver authority to assist in funding the Montana Reinsurance Program. The program will
reimburse health insurance insurers for certain high-cost claims in the individual health insurance
market.
In the CSI's Advisory Memorandum dated April 5, 2019, insurers were notified that they would
be required to comply with Section 5 of Senate Bill 125 (now ยง 33-22-1307(1)(f) MCA) which
provides that the Commissioner shall "require all eligible health insurers to calculate the premium
amount the eligible health insurer would have charged for the benefit year if the Montana
reinsurance program had not been established" as part of their rate filing.
The CSI is confident that the Waiver application will be approved. However, in an abundance of
caution, this guidance is issued to inform insurers that they will have the opportunity to resubmit
rates for individual marketplace plans should the Waiver application be denied. In the event this
occurs, the CSI will provide further guidance regarding the timeline for such resubmission.
If you have questions, please contact Pam Koenig, Actuary/Health Team Lead (pkoenig@mt.gov)
or call the CSI at 406-444-2040.
Phone: 1-800-332-6148 / (406) 444-2040 / Main Fax: (406) 444-3497
Securities Fax: (406) 444-5558 / PHS Fax: (406) 444-1980 / Legal Fax: (406) 444-3499
840 Helena Ave., Helena MT 59601 Website: www.csi.mt.gov E-Mail: csi@mt.gov