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IDOI Bulletin for 2016 Health Plan Renewals

Posted on April 2nd, 2015

The Illinois Department of Insurance (IDOI) issued a bulletin on March 20, 2015 as it relates to the renewal of certain health plans in 2016. In particular, the bulletin indicates that certain health plans may continue to be renewed for plan years on or before October 1, 2016 without being considered out of compliance with Affordable Care Act (ACA) regulations.  
 
The bulletin impacts the following plan types: 
 
  • Non-grandfathered individual health plans purchased prior to January 1, 2014 (sometimes referred to as grandmothered plans) and which will be renewing between January 1, 2016 and October 1, 2016.  As an example, a person that has an individual health plan as identified above with a renewal date of July 1, 2016 will be able to maintain that coverage until June 30, 2017.
     
  • Non-grandfathered small group health plans purchased prior to January 1, 2014 and which will be renewing between January 1, 2016 and October 1, 2016.  As an example, an employer that has a small group plan as identified above with a renewal date of October 1, 2016 will be able to maintain that coverage until September 30, 2017.
     
  • Employers that are currently purchasing coverage in the large group market but will be redefined as part of the small group market starting in 2016 (employers with 50-100 employees) and which will be renewing between January 1, 2016 and October 1, 2016. As an example, an employer of this size and in this situation with a plan renewing on January 1, 2016 will be able to maintain that coverage until December 31, 2016.    
     
The bulletin does not require an insurer to continue or renew any of the above mentioned plans, but insurance companies are supposed to notify the DOI of their intention by April 15, 2015.
 

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The materials contained within this communication are provided for informational purposes only and do not constitute legal or tax advice. 
   

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