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Life and Health Product Review

Frequently Asked Questions


  • 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 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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  • 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 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 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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  • 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 69O-150, 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 69O-223, F.A.C.

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  • 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 filing.

Also see additional requirements in web sites for Life & Health Rate Filing Requirements and Life & Health Form Filing Requirements.

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