General Filing Instructions - revision project (updated December 6, 2018)
At least annually, the Rates & Forms division (R&F) of the Office of the Insurance Commissioner updates the Washington State SERFF Health and Disability Form Filing General Instructions and Washington State Health and Disability Rate Filing General Instructions (collectively the GFIs) in order to reflect changes in state and federal law and rules. For the last few years, the revision has occurred early in the calendar year, timed to address new requirements from HHS's annual Payment Rule for individual and small group health plans, changes to System for Electronic Rate and Form Filing (SERFF) Plan Management, and updates to the CMS Qualified Health Plan templates.
Although R&F anticipates updating the GFI in early 2019 per usual (when the as-yet-unreleased HHS Payment Rule is finalized), we are taking the opportunity to consider overall revisions to the GFI when we and our regulated entities are not under the time crunch of preparing for the Plan Year 2020 (PY20) individual and small group health plan filings. To that end, we will be undergoing a GFI re-write of the following:
- Washington State SERFF Health and Disability Form Filing General Instructions
- Washington State SERFF Health and Disability Rate Filing General Instructions
- Washington State SERFF Life and Disability Rate and Form Filing General Instructions
- Washington State SERFF Health and Disability Binder Filing General Instructions
We are revising the Life and Disability GFIs at the same time as the Health and Disability GFIs due to the overlap of health plan content.
Our first step was to solicit feedback from our stakeholders. We are now posting initial drafts based upon that first round of feedback. These drafts are still very rough (the formatting is off), but we think it's important to share what we're thinking as we continue to move forward with the revisions. One big change is that we are simplifying the GFI content and creating what we are calling Speed to Market Tools to help carriers get to approval faster. Please let us know what you think of this effort.
We are requesting feedback on these draft GFI's and Speed to Market Tools to be submitted to R&F by January 4, 2019. Our goal is still to post new GFI's, incorporating that feedback, early in 2019.
Please remember that R&F accepts feedback on the GFIs all year long. If you miss providing feedback by January 4, 2019, please still provide us with your comments. We will do our best to review and incorporate them.
How to provide feedback:
- We suggest, for clarity, that you download a copy of the draft GFIs and Speed to Market Tools and make your suggestions directly in those documents.
- Please submit separate comments for each GFI.
- Please consolidate company feedback into one email.
Health and Disability
Life and Disability