Guidance on Annual Submission of Complaint and Appeal Information

The State of New Hampshire Insurance Department 21 South Fruit Street, Suite 14 Concord, NH 03301 David J. Bettencourt Keith E. Nyhan Commissioner Deputy Commissioner BULLETIN Docket #INS 26-001-AB TO: All New Hampshire Health Carriers, Licensed Entities Offering Group Health Plans and Employee Benefit Plans, and Medical Utilization Review Entities FROM: Commissioner David J. Bettencourt DATE: January 15, 2026 RE: Information I. Introduction New Hampshire law requires licensed health carriers and other regulated entities to maintain internal appeal procedures for claim denials and to make complaint and appeal information available to the Insurance Department for market-conduct oversight pursuant to RSA 415-A:4-b, V(f) and RSA 420-J:5, V(f). II. Purpose & Scope This bulletin provides guidance on the format, timing, and method of submission for annual complaint and appeal information for managed care plans that regulated entities are already required to collect and maintain under existing law. The guidance applies beginning with the April 1, 2026 filing and is intended to promote consistent administration of statutory requirements and uniform reporting practices across the market. III. Background The Department conducts market-conduct oversight through a combination of statutory reporting, the NAIC Market Conduct Annual Statement (MCAS), complaint monitoring, and other established regulatory tools. While these mechanisms remain in place, experience has shown that certain information required by statute is not consistently submitted in a uniform or administratively usable format. In March 2025, the Department issued guidance delaying enforcement of certain reporting requirements until the Department could issue clarifying expectations for existing market-conduct reporting obligations, including submission format and Telephone 603-271-2261 • Fax 603-271-1406 • TDD Access: Relay NH 1-800-735-2964 insurance.nh.gov Guidance on Annual Submission of Complaint and Appeal timing, following a period of regulatory transition. This approach reflects a focus on clear, uniform standards that advance consumer protection while avoiding unnecessary administrative burdens that do not add measurable value. IV. Reporting Requirements Beginning with the filing due April 1, 2026, all entities within scope shall submit an annual summary of complaint and appeal information for the preceding calendar year using the standardized template provided by the Department, located at https://mm.nh.gov/files/uploads/nhid/documents/managed-care-annual-complaint­ and-appeal-template.xlsx. For the April 1, 2026 filing only, submissions shall include data covering calendar years 2024 and 2025. Thereafter, submissions shall be required annually for the immediately preceding calendar year. The Department notes the following: • The reporting described in this bulletin is limited to information that regulated entities are already required to maintain under existing statute. • This guidance does not require the creation of new data categories or reporting systems. • Prior authorization data is not included, as it is addressed through separate, existing reporting requirements. V. Method of Submission All submissions shall be made electronically using the MS Excel workbook provided by the Department and transmitted via email to healthcareanalytics@ins.nh.gov. The prescribed format is intended solely to promote administrative efficiency, consistency, and the protection of personal information. VI. Administration The reporting requirements described in this bulletin are administered pursuant to existing statutory authority and apply uniformly to all regulated entities within scope. Information submitted will be reviewed in the ordinary course of the Department’s market-conduct oversight activities. Failure to submit required information in the manner described may be addressed in accordance with applicable law. VII. Questions Questions regarding this bulletin or the reporting template may be directed to the Department’s Health Care Analytics Unit via email at healthcareanalytics@ins.nh.gov or by calling 603-271-2261. Page 2 of 2