Life and Health Product Review
Frequently Asked Questions
FORM ONLY FILINGS
- Does Florida have statutes and rules that outline the requirements for the filing
Answer: Yes, see Sections
627.413, F.S. and
Rule 69O-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 in this web site. You may also call
the Bureau of Life & Health Product Review at 850-413-3152, 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.
- 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 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 Office of Insurance
Regulation 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 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 Office of Insurance Regulation 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 Office will email a letter of acknowledgement
to let you know the Office's file number, the analyst and the telephone number
and email address
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
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 69O-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
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
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
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- 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
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 Office of Insurance Regulation 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
F.A.C. Medicare supplement advertisements are regulated pursuant to Rule
69O-156, F.A.C. Life
advertisements and annuities sold through financial institutions are regulated
pursuant to Rule
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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 should be completed pursuant to the
Universal Standardized Data Letter Instructions for a form and rate
Also see additional requirements in web sites for
Life & Health Rate Filing Requirements and
Life & Health Form Filing Requirements.
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