- Insurance Regulatory Insights
- Posts
- August 2025
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The first Tuesday of each month, Telos Actuarial brings you legislative and regulatory insurance insights from around the nation.
The newsletter is grouped into four categories:
Final: approved legislature, state bulletins, and final federal rules
New: proposed bills recently introduced for consideration by legislature and proposed federal rules
Movement: bills that have progressed in legislative process
Fail: bills that have died in committee or failed to pass
👀⚖️ Are you interested in how the One Big Beautiful Bill Act, signed into law by President Trump on July 4, 2025, will impact Medicare? ⚖️👀
Check out the most recent Medicare Market Insights newsletter here!
Final: approved legislature, state bulletins, and final federal rules
Medicare Supplement
Rhode Island
Effective Date: July 2, 2025
Summary: The health insurance commissioner shall evaluate adopting a community rating structure for Med Supp plans, and report/file findings and recommendations on or before January 1, 2026.
Removes previous provision of GI rights during an annual enrollment period, replacing with:
a 6-month OE period for individuals U65 who qualify for Medicare due to disability or ESRD upon reaching 65;
U65 individuals enrolled in a MA plan or Med Supp Plan A due to disability or ESRD have GI rights for any Med Supp Plan A made available in the state; and
Individuals who have been covered by a Med Supp policy or MA plan with no gaps in coverage greater than 90 days beginning from the individual's Medicare Initial Enrollment Period (IEP), will be afforded GI rights for any Med supp policy available in the state, annually during the Medicare Annual Enrollment Period (AEP) for coverage effective January 1 of the following year.
Nevada
Bill/Notice Number: SB292
Effective Date: October 1, 2025
Summary: 1) An insurer shall offer a person who is less than 65 years of age and eligible for and enrolled in Medicare on the basis of a disability or ESRD to purchase any Med Supp policy that the insurer offers to new insureds who are 65+ with the same terms, limitations, and conditions.
These eligible individuals will have an OE period beginning:
a) October 1, 2025, through April 1, 2026; or
b) on the first day of the first month that the person enrolled in coverage pursuant to Medicare Part B for six months. During this OE period, issuers can't deny based on health status, claims experience, and pre-existing conditions.
For plans Plan A, Plan B or Plan D, cannot charge a premium rate that exceeds the premium rate that the insurer would charge a person who is exactly 65 years of age for the same Med Supp policy.
For all other plans, a premium rate that exceeds 200 percent of the premium rate that the insurer would charge a person who is exactly 65 years of age for the same Med Supp policy.
2) Revises existing annual OE "Birthday Rule" period to not allow exclusion of benefits based on pre-existing conditions.
Wyoming
Bill/Notice Number: Bulletin 06-2025 (clarification)
Summary: Provides further clarification regarding "Birthday Rule" implementation, effective June 4, 2025. It is the Department’s position that if a policyholder had their birthday on or before June 4, 2025, but were still within the 63-day GI window, the insured would be eligible for the birthday rule GI period until the conclusion of the sixty-third day after the insured’s birthday.
Texas
Bill/Notice Number: Bulletin B-0010-25
Summary: Provides clarification to insurers on how to implement HB2516, which creates Med Supp enrollment and rating protections for U65 individuals due to ESRD or ALS on or after September 1, 2025. Revised forms and rates should be submitted to the TDI by August 1, 2025.
Medicare Advantage / Part D
New Hampshire
Bill/Notice Number: SB121
Effective Date: September 13, 2025
Summary: Any licensed insurance company offering Medicare Advantage Plans in the state should provide 90 days' written notice to the commissioner when modifying or terminating its contract with CMS, ceasing to offer MA plans in a particular county, or significantly modifying the offerings of its MA plans.
Hospital and Other Fixed Indemnity
Alabama
Bill/Notice Number: July 10, 2025 Memorandum
Summary: Rescinds Bulletin 2024-02, which provided filing requirements for the Tri-Agency Federal Disclosures.
Medicare
CMS
Bill/Notice Number: CMS-1833-F and CMS-1808-F
Summary: Final Rule - Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals (IPPS) and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year (FY) 2026 Rates.
New: proposed bills recently introduced for consideration by legislature and proposed federal rules
Medicare Supplement
Michigan
Bill/Notice Number: SB469
Summary: Allows for open enrollment for non-age-eligible individuals during the six-month period after the individual enrolled in Medicare Part B. Non-age-individuals who were enrolled in Medicare Part B prior to the effective date of the regulation will be eligible for open enrollment during the six-month period after the effective date of the regulation. Insurers shall not charge non-age-eligible individuals more than an individual who is 65 years of age, and the policy cannot include a waiting period or pre-existing condition limitation/exclusion.
Also allows for a 60-day OE period after an individual’s date of birth, when the individual is insured under a Med Supp policy and submits an application for the same Med Supp policy to a different insurer.
Medicare
CMS
Bill/Notice Number: CMS-1832-P
Summary: Proposed Rule - Calendar Year 2026 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program.
Bill/Notice Number: CMS-1834-P
Summary: Proposed Rule - Calendar Year 2026 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; Quality Reporting Programs; Overall Hospital Quality Star Ratings; and Hospital Price Transparency.
Congress
Summary: Proposed bill (Choose Medicare Act) that would establish and allow individuals and employers to voluntarily enroll in Medicare Part E, a self-funded Medicare plan to be offered to individuals of any age or employment status alongside private insurance in all state and federal marketplaces.
Movement: bills that have progressed in legislative process
Medicare
Massachusetts
Summary: Medicare, Medicare Advantage, and MassHealth providers and suppliers may not bill Medicare beneficiaries in the Qualified Medicare Beneficiary eligibility group for Medicare Part A or Part B cost-sharing.
Fail: bills that have died in committee or failed to pass
Medicare Supplement
Oregon
Bill/Notice Number: SB1181
Summary: Prohibits denial of a Medicare supplement insurance policy due to a preexisting condition and charging different rates based on health status, claims experience, and medical condition:
prior to or during the 6-month period beginning with the first day of the month the individual enrolled in Medicare Part B; or
during an annual 60-day OE period that begins January 1 each year.
Telos Actuarial’s team of experienced regulatory compliance professionals are ready to help YOU stay informed of legislative and regulatory changes. Reach out to us for more information!