Welcome to the
Office
of Insurance Regulation
Life and Health Product
Review
Frequently Asked Questions
FORM ONLY FILINGS
- Does Florida
have statutes and
rules that outline
the requirements for
the filing of forms?
Answer: Yes, see
Sections
627.410,
627.411 and
627.413, F.S. and
Rule 4-149.021, F.A.C.
- Can I find
additional instructions
to assist me in putting
my filing together?
Answer: Yes, see the
Universal Standardized Data
Letter Instructions [Word
|
pdf] in this web site.
You may also call the Bureau
of Life & Health Forms and
Rates at 850-413-5112, and
ask for an analyst to review
the requirements for any
specific type filing.
- How long does it
take for a filing to be
reviewed?
Answer: If the filing is
complete it should take two
weeks.
- What if I can’t
make the response
deadline indicated
in your letter?
Answer: Call the
analyst to see if an
extension can be
granted.
Answer: Yes, a fax or
e-mail response is
acceptable. However, if
the response includes a
form submission or
revision, a final print
will ultimately need to
be submitted. Please
keep a response by fax,
to less than 10 pages.
- Can I change a
previously approved
form.
Answer: Yes, however, all
form changes must be
submitted pursuant to
Section 627.413, F.S.
- Can I submit more
than one policy form in
the same filing?
Answer: Yes, as long as
the policies are of the same
type.
- What can I do to
speed up my forms
review?
Answer: Review the
filing rules and
Universal Standardized
Data Letter Instructions
[Word
|
pdf] prior to
putting your filing
together. Incomplete
filings will be
returned. Include
detailed information in
your letter of
transmittal. Describe
the type of policy
submitted. Identify
whether or not it is a
resubmission, a
replacement or a new
policy. Give the
Department of Insurance
previous assigned file
number and date of
action taken if this is
a replacement or
resubmission. Include
copies of all prior
correspondence for a
resubmission. Give a
full explanation as to
how the product will be
marketed. If the product
is to be solicited and
or delivered over the
Internet, give a
detailed explanation as
to how the electronic
marketing and delivery
of the product will
comply with Florida
Statutes and rules that
would apply if the
product was sold and
delivered through
traditional means.
- What is required
when I submit a filing
for a rider, amendment
or endorsement?
Answer: Submit the
Universal Standardized Data
Letter [Word
|
pdf] and all other form
filing requirements except
for a checklist and
checklist certification.
This means you will need to
include a readability score
and certification. Please
identify in the letter of
transmittal the policy forms
to which the forms
submitted, will be attached.
Include the previous date of
approval of these forms and
the Department of Insurance
file numbers assigned to the
previously approved forms.
- Who should I contact
regarding a filing that
is currently under
review?
Answer: Upon receipt of a
new filing, the Department
will fax a letter of
acknowledgement to let you
know the Department’s file
number, the analyst and the
telephone number of the
analyst assigned to the
filing.
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RATE
ONLY FILINGS
- We're filing
endorsements or riders
to a previously approved
life or annuity form. Do
we still need an
actuarial memorandum?
Answer: The actuarial
memorandum must adequately
demonstrate that reserves
will comply with
Section 625.121, F.S.
(as well as all other laws),
for riders, amendments, and
endorsements, as well as the
base contract, to satisfy
Rule 4-149.021(1)(b)8, F.A.C.
If the changes do not affect
reserves, we will need such
a statement certified by a
qualified actuary (MAAA)
stating specifically that
reserves are unaffected by
the inclusion of the forms
being submitted for review.
- Our group life
contract is designed to
be marketed to Florida
groups. The master
contract is issued to a
non-Florida trust. Would
that make it an in-state
or out-of-state filing?
Answer: Out-of-state. If
this policy may be offered
to an out-of-state group --
including a trust -- formed
primarily for the purpose of
insurance, in accordance
with Section
627.5515(2)(a), F.S.,
please provide a detailed
numeric actuarial
demonstration of the
following: (a) Benefits are
reasonable in relation to
premiums (See Section
627.411(2), F.S. If loss
ratios are used for this
demonstration, please note
that ratios below 55% are
generally unacceptable.);
and (b) Economies of
administration will result
from issuance to the group
(e.g., dollar savings as
compared with issuing this
directly to Florida groups).
- We want to update
our life insurance
rates, e.g., schedule of
Cost of Insurance (COIs)
or premiums. What do we
need to file?
Answer: Usually nothing.
If rate changes on life
insurance do not change the
nonforfeiture basis, and do
not affect the form as
previously approved, rate
changes (including COIs on
universal life) do not
generally need to be filed.
If submitted, such filings
will usually be returned
without review.
- What experience
needs to be provided in
an individual product
rate filing?
Answer: Calendar year
experience since inception
is to be provided for both a
Florida only and nationwide
basis, showing the year,
collected premium, earned
premium, paid claims, paid
loss ratio, change in claim
and claim liability
reserves, incurred claims,
incurred loss ratio,
expected incurred claims,
actual to expected claim
ratio, and active life
reserves. Within each
calendar year, experience is
to be provided by issue year
or duration. In addition,
experience should be shown
on both an actual and
constant premium basis.
Future projected experience,
on both a Florida and
nationwide basis, should
display the year, earned
premium, incurred claims,
and incurred loss ratio.
These projections should be
provided both with and
without the currently
requested rate increase. The
projections should assume
future rate schedule
increases of the same
magnitude as any medical
trend that is projected.
- Are modal loadings
included in the earned
premium?
Answer: Yes, all modal
loadings, policy fees and
other components of the
premium paid are included in
the earned premiums reported
in the past and projected
experience.
- What must be
submitted with a rate
schedule?
Answer: The rate schedule
includes all aspects of the
schedule used to determine a
final rate, this includes
all rating factors,
underwriting class factors,
modal factors, policy fees
or other add on expenses.
Group coverage also requires
any experience rating
formula used, credibility
table, underwriter
adjustment allowances, or
any other item which would
change or determine a rate
charged which does not come
directly from the rating
manual.
- What is included in
incurred claims in
determining loss ratios?
Answer: Incurred
claims include the payment
of medical care or services
to the insured, including
the reserve for open or
incurred but not reported
claims. It does not include
active life reserves,
expenses, litigation costs,
punitive damage awards, etc.
The cost of managed care,
pre-certification,
utilization review, etc are
considered expense and not
part of incurred claims.
- Could individual
policies have a
guaranteed period where
rates will not be
increased?
Answer: No. If this were
permitted, the result after
a rate increase would be
that two insureds would have
different rates solely based
on the duration.
Section 627.410
prohibits rating schedules
where rates are impacted by
the duration.
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ADVERTISEMENT FILINGS
- What types of
advertisements are
required to be filed?
Answer: Only
advertisements for long term
care, Medicare supplement
and small group products are
required to be filed.
- What filing forms
are required to be filed
with advertisements?
Answer: There are no
filing forms required.
However, completion of the
Universal Standardized Data
Letter [Word
|
pdf] will help in the
accurate and quick
processing of your filing.
- What information is
requested about the
advertisement or the
products described?
Answer: The letter of
transmittal should identify
the type of product being
advertised. When a specific
product is being advertised
the letter of transmittal
should give the form number
of the product advertised,
the Department of Insurance
file number assigned to the
product when approved and
the date of approval.
- What are the
regulatory cites for
advertisements?
Answer: All health
advertisements except for
Medicare supplements are
regulated pursuant to
Rule 4-150, F.A.C.
Medicare supplement
advertisements are regulated
pursuant to
Rule 4-156, F.A.C. Life
advertisements are regulated
pursuant to
Rule 4-151, F.A.C.
Annuities sold through
financial institutions are
regulated pursuant to
Rule 4-223, F.A.C.
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FORM & RATE FILINGS
- What filing forms
are required to be
submitted with a new
product filing that
includes forms and
rates?
Answer: The Universal
Standardized Data Letter [Word
|
pdf] should be completed
pursuant to the Universal
Standardized Data Letter
Instructions [Word
|
pdf] for a form and rate
filing.
Also see additional
requirements in web sites
for
Life & Health Rate Filing
Requirements and
Life & Health Form Filing
Requirements. A filing
for a new product including
forms and rates should be
submitted under one letter
of transmittal and not
separately. Send three sets
of the filing.
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