🎉 Exciting News 🎉

Since starting Insurance Regulatory Insights in April 2024, we have sent 51 newsletters to keep you updated on proposed and/or recently approved legislation, CMS notifications, and state department of insurance communications.

We are excited for Insurance Regulatory Insights to take the next step!

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Included with your subscription is our new tool, Reg Tracker – a comprehensive list of insurance regulatory actions in all states for this calendar year that are included in the newsletters.

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The first Tuesday of each month, Telos Actuarial brings you legislative and regulatory insurance insights from around the nation for the following insurance products:

  • Medicare Supplement

  • Part C (Medicare Advantage)

  • Part D (Prescription Drug)

  • Hospital / Other Fixed Indemnity

  • Critical Illness and Dread Disease

  • Senior Dental

  • Accident and AD&D

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

Final: approved legislature, state bulletins, and final federal rules

Medicare Advantage

Effective Date: August 18, 2025

Summary: A district judge in Texas vacated the provision in the April 2024 Final CMS Rule that fixed broker and agent compensation and raised the pay cap for new enrollments. However, the court did uphold the provision requiring banning third-party marketing firms from distributing personal beneficiary data to other marketing organizations without consent.

Dental

IL

Bill/Notice Number: SB1392

Effective Date: January 1, 2026

Summary: Provides that no provision of the Illinois Insurance Code, or any other law, prohibits assignability rights to an insured under any policy of dental insurance (in addition to accident and health insurance). Also revises existing code to add that if a claim is assigned to a dental care provider or a dental care facility, then payment shall be made directly to the dental care provider or dental care facility, including any required interest.

Short-Term Limited-Duration Insurance (STLDI)

CMS

Bill/Notice Number: August 7, 2025 Memorandum

Summary: Provides a statement that the U.S. Departments of Labor, Health and Human Services, and Treasury do not intend to prioritize enforcement actions for violations related to failing to meet the definition of STLDI in the 2024 final Tri-Agency rules, including the notice provision. HHS encourages states to adopt a similar approach to enforcement. HHS will not consider a state to be failing to substantially enforce the relevant individual market requirements under the PHS Act or ACA where a State adopts a similar approach to enforcement or applies its state law definition of STLDI.

The Department of Health and Human Services also issued a statement.

IA

Bill/Notice Number: Bulletin 25-05

Summary: In September 2024, the Tri-Agency Final Rule changed the allowable duration of STLDI plans from up to three years to a maximum of four months. On August 7, 2025, the federal government announced it will not “prioritize enforcement actions” against states that apply the “state law definition of STLDI insurance.” Effective immediately, the Division will allow authorized carriers to sell STLDI plans for an initial term of up to 12 months with renewals permitted to extend the total coverage period up to 36 months. Carriers that have not already received the Division’s approval to sell these plans must seek prior approval.

NC

Bill/Notice Number: Bulletin 25-B-11

Summary: Advises all carriers that the current definition for STLDI in 45 C.F.R. § 144.103 remains the definition for STLDI health insurance in North Carolina. No STLDI product regulated by the Department of Insurance may be offered in North Carolina that does not comply with the standards set by the current federal rule. The U.S. Departments of Labor, Health and Human Services, and Treasury's statement of non-enforcement does not change what the current law is and because North Carolina statutes are tied to the federal definition the Department of Insurance will continue to follow the federal definition for STLDI.

Medicare

CMS

Bill/Notice Number: CMS-1827-F

Effective Date: October 1, 2025

Summary: Final Rule - Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program for Federal Fiscal Year 2026.

CMS

Bill/Notice Number: CMS-1831-F

Effective Date: October 1, 2025

Summary: Final Rule - Medicare Program; FY 2026 Inpatient Psychiatric Facilities Prospective Payment System-Rate Update.

CMS

Bill/Notice Number: CMS-1829-F

Effective Date: October 1, 2025

Summary: Final Rule - Medicare Program; Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2026 and Updates to the IRF Quality Reporting Program.

CMS

Bill/Notice Number: CMS-1835-F

Effective Date: October 1, 2025

Summary: Final Rule - Medicare Program; FY 2026 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Program Requirements

All Products

AK

Bill/Notice Number: SB132

Effective Date: January 1, 2026

Summary: Revises the Grace Period provision required in health insurance policies in which the insurer reserves the right to refuse renewal by changing the notice timeframe for intent to not renew beyond the period that premium has been accepted from 30 to 45 days.

ND

Bill/Notice Number: Bulletin 2025-1

Summary: Bulletin regarding Insurance Data, Security and Event Reporting, which all individuals and entities required to be licensed by the Insurance Department, including insurance companies, producers and agencies, TPAs, MGAs, and other licensed organizations are subject to.

VA

Bill/Notice Number: Bulletin 2025-03

Summary: Provides requirements and qualifications for Domestic, Foreign, and Alien Insurance Companies seeking admission to do business in Virginia.

Movement: bills that have progressed in legislative process

STLDI and Fixed Indemnity

Congress

Bill/Notice Number: S2641

Summary: Proposed bill providing that the rule relating to "Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage" (89 Fed. Reg. 23338 (April 3, 2024)) shall have no force or effect.

With a paid subscription, you can see these updates in Reg Tracker, a comprehensive list of insurance regulatory actions in all states for this calendar year that are included in the newsletters.

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!