In conjunction with the Locke Lord COVID-19 task force, we are reviewing, analyzing, and compiling regulatory updates to provide clients easy access to information during this unprecedented time.  If you have any questions on the subject matter below, do not hesitate to reach out.  The information below relates to state and federal bulletins, emergency orders, pending/enacted legislation, and other related actions taken in response to the COVID-19 pandemic.

All Lines of Insurance

D.C.:  On May 8, the Department of Insurance and Banking issued Bulletin 20-IB-2-05/08, providing guidance to all licensed premium finance companies related to Commissioner’s Order 03-2020. The Bulletin discusses interpretive guidance on the application of the prohibition on cancellations and the 12 months of deferred payments for unpaid premiums.

Delaware:  On May 13, the Delaware Insurance Commissioner approved revisions to the Delaware Basic Manual and the Delaware Statistical Plan Manual.  The filings revise the Delaware Basic Manual and Statistical Plan Manual regarding:

  • payroll rules;
  • temporary classification adjustments related to temporary reassignment of duties;
  • a statistical code to capture payroll of employees who are paid but not working;
  • the exclusion of losses on experience rating and merit rating plans; and,
  • audit reporting requirements.

Maryland:  On May 13, the Governor of Maryland issued Order 20-05-13-01, stating that certain restrictions on non-essential businesses have been eased.

New Hampshire:  On May 13, the New Hampshire Insurance Department issued Bulletin Ins. 20-034-AB extending for one-month insurance producer license renewal deadlines for all renewals originally due by May 31.

Wisconsin:  On May 14, the Wisconsin Supreme Court ruled in a 4-3 majority to strike down Governor Evers’ Safer at Home executive order.

Health Insurance

Utah:  On May 13,  Commissioner Kiser issued Bulletin 2020-13, providing insurers guidance concerning federal requirements for coverage of COVID-19 testing. The Bulletin reminds insurers that on March 18, 2020, the Families First Coronavirus Response Act (FFCRA) went into effect to ensure that Americans will not have to pay for COVID 19 testing.