Dear Health Insurance Industry Representatives:
The Department has heard from some carriers that our decision to require a carrier to participate in all counties within a certain rating/service area was made on May 14, 2013, limiting the options available to the carriers. The Department had provided directions through the SERFF system on this issue and others that were available to all carriers in late March. In directions regarding partial service areas, the Department instructed “Do Not Implement” and indicated “Tennessee aligned the service areas with our rating areas and if you are going to offer coverage in a rating area, you must cover all the counties in that rating area.”
Tennessee decided in mid-March to utilize the Plan Management functionality of SERFF for the off-exchange filings and to require such filings to contain the same templates as the exchange filings. For your convenience, we have attached a copy of what was sent to SERFF (Copy of State Implementation). The PM GI tab shows the filing requirements and under “Outside Market” specifies that we have the same filing requirements for both inside and outside the exchange. We have also attached a spreadsheet (Copy of 032513 Review with States) that lists specific questions for supporting documentation that was sent to SERFF. These instructions on SERFF specify that Tennessee does not allow actuarial equivalent substitutions and that carriers must cover all counties in a rating area.
The Department cannot emphasize enough the need to use the SERFF system and to review SERFF guidance in preparing filings. Guidance that we enter into the SERFF system should be reflected in company filings. Per TCA §56-26-102(c), all filings for accident and sickness rates and forms for individual and small employer coverage made after January 1, 2012 shall be filed electronically through SERFF, which is the entity designated by the Commissioner to receive those electronic filings. The SERFF program is meant to make the filing process more efficient for carriers and the Department.
To follow-up on questions that we have received from many of you regarding off-exchange filings, the Department has agreed to extend the deadline for off-exchange filings to June 15, 2013. The items below must be filed with the Department.
Carriers do not need to file a PDF of their rates as long as the Rate Data template is included in the prescribed .xls format.
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