How will the rates be treated for the PPACA filings?
The current rating statutes apply. However, it is important to note that the new Medical Loss Ratio standards become effective Jan. 1, 2011. These new standards must be reflected in new rate filings. Also, the Department of Health and Human Services is establishing guidelines to define ‘unreasonable’ rate increases. Additional filing requirements may be required when the new regulations are developed.

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1. If a company already complies with a PPACA requirement, do they have to file anything with the Department of Insurance?
2. What plans are considered grandfathered?
3. What immediate health insurance reforms affect grandfathered plans for form filing requirements?
4. How should the changes to the grandfathered plans be submitted to the department?
5. What are the plans effective March 24 through September 22, 2010 considered; grandfathered or non-grandfathered?
6. What reforms affect the plans in effect March 24, 2010 through September 22, 2010?
7. Can the changes to the non-grandfathered plans be made via amendment or does a new product have to be filed?
8. What are the filing requirements for the prohibition of discrimination based on salary since it is not included on the Uniform Compliance Summary?
9. What are the filing requirements with regard to the internal and external review processes?
10. How will the rates be treated for the PPACA filings?