Getting Started with the Compact
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- Candace Fleming
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2 Overview Structure of Individual Long-Term Care Uniform Standards Compact Filing and Review Process Types of iltc Product Filings Approved Five-Year Review of iltc Standards
3 The IIPRC Today
4 Getting Started with the Compact Visit the Insurance Compact website - Contact IIPRC Office with any questions or to set up a one-on-one webinar 4
5 Structure of iltc Uniform Standards Compact Statute requires LTC Uniform Standards must provide same or greater protections based on NAIC LTC Model Law and Regulation Authority to develop uniform standards and approve LTC rate and advertising filings
6 Structure of iltc Uniform Standards Multiple rounds of public comments and deliberative, thoughtful discussion with broad input Adopted August 13, 2010 and effective December 1, 2010 Currently undergoing 5-year review process
7 Structure of iltc Uniform Standards Scope - products advertised, marketed or offered as long-term care insurance (not less than 12 consecutive months) with benefits used for one or more of the following: nursing home care, assisted living care or home health care and adult day care Products Traditional LTC product Accelerated Death Benefit Rider for LTC Enhanced LTC Benefits Rider
8 Structure of iltc Uniform Standards Ten Uniform Standards Application Application Forms Change Application Core Form (Policy/Rider) Benefit Features Amendments Outline of Coverage Advertisements
9 Structure of iltc Uniform Standards Issue Age Rates Modified Rates - not permitted in Colorado, Illinois, Maryland, Oklahoma, Oregon and Washington Arizona, Hawaii, Indiana, Montana, and New Jersey have opted out (Nevada lifted opt-out in 2013) Filing Information Notice (Updates and Replaces FIN ): Individual Long-Term Care Filings
10 Structure of LTC Uniform Standards Rate Requirements IIPRC reviews initial rates Rate increases for 15% or less to be filed with IIPRC Rate increases for more than 15% to be filed with Compacting State and with IIPRC making an advisory finding
11 Structure of LTC Uniform Standards Partnership IIPRC approval does not equal approval for use in state Partnership program Compacting State can check IIPRC-approved forms for Partnership requirements (other than state-specific form requirements) Companies use Statement of Variability and brackets to denote state-specific Partnership requirements
12 Filing Process for Long-Term Care Prior review of all IIPRC product filings Self-certification Allowed only if explicitly specified in Uniform Standard Allowed for forms required to be used with iltc applications Required to review filings in 60 days or less Does not include industry response time Assumes product filing is substantially compliant with Uniform Standards
13 Filing Process for Long-Term Care Three Filing Submissions Per Product 1. Policy/Riders/Rates/Outline of Coverage 2. Self-Certified Forms Suitability Forms Potential Rate Increase Disclosure Form Replacement Notice HIPAA Medical Authorization 3. Advertising Forms
14 Filing Process for Long-Term Care Rates Rates filed with applicable policy forms Actuarial Memorandum, Rate Schedules, Pricing Assumptions (Sample on website) Annual actuarial certification is required to be filed by Dec. 31 of each year after approval Updated actuarial memorandum filed every three years
15 Filing Process for Long-Term Care Advertising One unique advertising filing associated with each iltc product filing Advertising filings are re-opened as needed to update or add new advertising materials that will be used with product Uniform Standards for advertising have very detailed requirements
16 Filing Process for Long-Term Care LTC Riders Comply with the applicable uniform standards for the life product Use the iltc uniform standards to develop the rider, outline of coverage, and supporting documentation Base life insurance policy generally UL, IUL, VUL, or whole
17 Filing Process for Long-Term Care LTC Riders $ for $ Life LTC Benefit Rider exempt from rate filing standards (actuarial information must support exemption) For extension of benefit riders or riders that do not fit the dollar-for-dollar exemption, rate schedules and supporting actuarial information must be submitted
18 Type of iltc Product Filings Approved Over 4,500 product approvals since % Life, 30% Annuities, 15% LTC 30+ full iltc Products 60+ iltc Riders Regulators have access within SERFF Everyone has access through SERFF Filing Access to view and access approved product filings
19 Type of iltc Product Filings Approved In general, filing new business rate schedules every 12 to 18 months No rate increase filings to date Companies with approved filings on or before 12/31/14 have at least one annual rate certification on file Triennial certification filed for 11 and 12 approvals Started receiving gender-distinct rate schedules in Fall 2012
20 Five-Year Review Process Scope of review the need for continuation, repeal or amendment of the rule based primarily on whether circumstances or underlying assumptions have changed since the last time the rule was adopted, amended or reviewed Product Standards Committee is presenting its recommendation to the Management Committee on August 25 th Formal rulemaking period will commence
21 Five-Year Review Process Amendments based on changes to NAIC LTC Model Regulation as well as Model Bulletin Substantive change recommended to add rate and actuarial requirements for $for$ iltc riders Substantive change requested by industry but not recommended by PSC to permit coordination / nonduplication provision to allow company to coordinate a pool of benefits among multiple policies (this issue has been raised to Innovations Subgroup and IIPRC would welcome input)
22 CONTACT IIPRC For more information, please contact us at: Phone: (202) Fax: (816)
23 Questions?
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