Bulletin 2020-01: Extension of Transitional Policy for Non-ACA Compliant Plans Through Calendar Year 2021

Uncategorized  |  March 11, 2020

On January 31, 2020, the Center for Consumer Information and Insurance Oversight (“CCIIO”) issued an Insurance Standards Bulletin extending CCIIO’s transitional policy through calendar year 2021, provided that all policies begin on or before October 1, 2021 and end by December 31, 2021. Previous bulletins referred to this topic as a “transitional policy” and CCIIO is now calling the policy a “non-enforcement policy,” but the substance of the policy remains unchanged from previous years. As with previous transitional policies, this policy applies to non-grandfathered health insurance plans in the individual and small group markets that would othe1wise terminate or require modification as a result of the federal health insurance market reforms required under the Patient Protection and Affordable Care Act (“ACA”).

In light of CCIIO’s extended transitional policy, insurers in Ohio may offer their insmeds the ability to continue/renew non-ACA compliant individual and small group coverage, at the insured’s option. Insurers wishing to extend coverage shall follow CCIIO’s transitional policy, including federal notice requirements, offering reenrollment or extended coverage to impacted policyholders in the individual and/or small group market in a uniform and non-discriminatory manner in accordance with Ohio law (Ohio Revised Code (“ORC”) 3924.03 and 3923.57). Thus, renewals shall be treated uniformly and without regard to health status.

Please note that individual coverage includes sickness and accident insurance made available in the individual market to individuals, with or without family members or dependents, through group policies issued to one or more associations, trusts, or other entities. Small group coverage applies to employer-sponsored plans only.

To take advantage of CCIIO’s transitional policy, filings must meet the requirements specified in the bulletin.

To access the bulletin in its entirety click here:


ODI’s bulletins page:


Thank you,

Ohio Department of Insurance