On January 19, 2021, the Center for Consumer Information and Insurance Oversight (CCIIO) issued an Insurance Standards Bulletin to extend the transitional policy (now referred to as a non-enforcement policy by CCIIO) that was originally announced on November 14, 2013 and subsequently adopted by the South Carolina Department of Insurance (Department) via Bulletin 2013-12 (November 19, 2013). This is the ninth in the series of bulletins relating to the transitional policy and its subsequent extensions.
The purpose of this bulletin is to advise health insurance issuers of the Department’s intent to continue to permit the renewal of coverage pursuant to the latest transitional policy extension. It is, further, to advise that the requirements outlined in the prior bulletins on this matter continue to remain in effect, as applicable.
This bulletin applies to health insurance issuers offering non-grandfathered health insurance coverage in the individual or small group markets for which coverage has continuously been renewed under this non-enforcement policy since 2014.
Importantly, South Carolina declines to enforce the 2014 market reforms that the federal government will not enforce for these specific policies. South Carolina will instead enforce its own laws during this transitional period extension.
The transitional policy permits issuers in the individual and small group markets to renew certain non-grandfathered policies that would otherwise be deemed out of compliance with the requirements of the Patient Protection and Affordable Care Act of 2010. Such coverage may now be renewed for plan or policy years beginning on or before October 1, 2022, so long as no such coverage extends beyond December 31, 2022.
Accordingly, health insurance issuers may renew early or amend the coverage term to permit consumers and small employers to maintain such coverage until December 31, 2022.
Health insurance issuers electing to renew coverage pursuant to this bulletin are reminded to review the prior bulletins linked to in the bulletin in their entirety in order to ensure compliance with the relevant transitional relief guidelines outlined therein.