September 2017 Edition of Alerts

Welcome to the September 2017 edition of the FORC Alert. If you have any colleagues that may be interested in this publication, please forward it on. There is a link on the Alerts main page where they can subscribe to receive FORC Alerts automatically.

Regards,
Ryan Smart, Esq., FORC Alert Editor
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Category(s): Florida - 09/27/2017

CMS Approves Florida’s Medicaid 1115 Waiver

On August 3, 2017, the Centers for Medicare & Medicaid Services (“CMS”) approved the extension of Florida’s Medicaid 1115 Waiver through June 30, 2022. Additionally, CMS determined the amount for the low-income pool’s uncompensated care pool to be approximately $1.5 billion annually. The agreement is contingent upon the Special Terms and Conditions (“STC”) outlined within the waiver.

Fred E. Karlinsky, Esq. - GREENBERG TRAURIG LLP, (954) 768-8278 , karlinskyf@gtlaw.com

Category(s): Florida - 09/27/2017

Commissioner Altmaier Says AOB Fix is Top Priority

During the Florida Cabinet meeting on August 16, 2017, a significant amount of time was spent receiving legislative budget requests (“LBRs”) from the various Cabinet agencies. Of particular interest was the comment from Insurance Commissioner David Altmaier during his presentation that his office’s top priority for the 2018 Legislative Session is securing passage of assignment of benefits (“AOB”) reform.
 
The 2018 Session, which begins January 9, will be the sixth session that OIR, Citizens Property Insurance Corporation (“Citizens”) and the industry have attempted to pass language to curtail the practice where contractors convince homeowners to sign over policy claims benefits and then submit inflated invoices. Commissioner Altmaier noted that the attorney fee framework encourages excess litigation which increases rates for consumers.
 
Agriculture Commissioner Adam Putnam, 2018 candidate for Governor, asked what could be done to address the problem without a statutory change. Commissioner Altmaier responded that OIR has approved policy form changes for Citizens and he expects to see private insurers mirror these form changes. New Chief Financial Officer (“CFO”) Jimmy Patronis, at his first Cabinet meeting since being appointed by the Governor, asked about the OIR’s efforts to educate consumers about this practice. In response, Commissioner Altmaier stated that a number of bulletins distributed to policyholders when Hurricanes Matthew and Hermine were approaching the state were designed to help homeowners know their rights, as well as aid them in identifying unsavory behavior from those who might take advantage. Reports received from homeowners during and after those storms indicate that the industry expanded its outreach to consumers to determine if they had a claim or needed assistance.
 
Governor Scott inquired about the AOB issue as it relates to vehicle windshields. Commissioner Altmaier explained that there is more AOB litigation on auto coverage regarding windshields than there are on property coverage but the key solution – attorney fees – is the same.

Fred E. Karlinsky, Esq. - GREENBERG TRAURIG LLP, (954) 768-8278 , karlinskyf@gtlaw.com

Category(s): Florida - 09/27/2017

CRC Announces Meeting Schedule

On August 9, 2017, the Florida Constitution Revision Commission (“CRC”) Rules and Administration Committee approved the schedule for meeting which coincides with the Florida Legislature’s schedule of interim committee meetings for the 2018 Session. The CRC will meet during the following weeks: September 18-19; September 26-28; October 3-5; October 31-November 2; November 28-30 and December 12-14.
 
Full Commission meetings are scheduled for September 19 from 9:00am-12:00pm EDT and October 17, 2017 from 9:00am-12:00pm EDT.

Richard J. Fidei, Esq. - GREENBERG TRAURIG LLP, (954) 768-8286 , fideir@gtlaw.com

Category(s): Florida - 09/27/2017

Florida Auditor General Report on Medicaid Managed Care Contract

Florida’s Auditor General recently released a report on the Statewide Medicaid Managed Care program which concluded that the Agency for Health Care Administration (“AHCA”) failed to adequately monitor managed care organizations (“MCOs”). The Report  also found that AHCA failed to identify the basis for the amount of liquidated damages levied against MCOs and obtain proper information to determine the damages.
 
The Report noted that AHCA failed to establish protocol and procedures to review the process for collecting social security numbers (“SSNs”). Further, it stated that AHCA should improve employee access to the Florida Accounting Information Resource (“FAIR”) Subsystem, use periodic independent assessments of organization controls for the VERSA Regulation system and provide greater accountability for state-owned property. It also noted that more accurate recordkeeping of tangible personal property acquisitions was needed.

Richard J. Fidei, Esq. - GREENBERG TRAURIG LLP, (954) 768-8286 , fideir@gtlaw.com

Category(s): Florida - 09/27/2017

Florida Commission on Hurricane Loss Projection Methodology Releases Flood Standards

On August 2, 2017, the Florida Commission on Hurricane Loss Projection (“FCHLPM”) released their 2017 Flood Standards.  The FCHLPM develops standards and reviews hurricane loss models. The models are used to develop residential property rates and calculate probable maximum loss levels. The FCHLPM charge was expanded to include reviewing flood loss models for personal lines residential loss in 2014. Linked below are the documents related to the 2017 Flood Standards:
•	Submission DataDefinitionsReferencesAcceptability ProcessCommission Principles

Richard J. Fidei, Esq. - GREENBERG TRAURIG LLP, (954) 768-8286 , fideir@gtlaw.com

Category(s): Florida - 09/27/2017

Florida Insurance Commissioner Issues Emergency Order

On September 13, 2017, Florida Insurance Commissioner David Altmaier issued an Emergency Order in the aftermath of Hurricane Irma. The purpose of the Emergency Order is to suspend and activate certain insurance rules and statutes for the purpose of public health and safety for Florida’s policyholders. The Emergency Order prohibits insurance companies from canceling or non-renewing policies covering residential properties damaged by Hurricane Irma for at least 90 days. Additionally, it allows 90 days to policyholders to supply information to their insurance company and prohibits any efforts to increase rates on policyholders for 90 days.

Fred E. Karlinsky, Esq. - GREENBERG TRAURIG LLP, (954) 768-8278 , karlinskyf@gtlaw.com

Category(s): Florida - 09/27/2017

FSLSO Releases Compilation of Financial Information for Insurers

On August 22, 2017, the Florida Surplus Lines Service Office (“FSLSO”) released financial information related to surplus lines insurers eligible to operate in the state. The information is designed to assist surplus lines agents and consumers with an interest in learning the financial strength of insurers operating in their area. The data contains information based on the following criteria: A.M. Best Rating; Capital and Surplus; Net Income; and Director Premium – both National and Florida.

Richard J. Fidei, Esq. - GREENBERG TRAURIG LLP, (954) 768-8286 , fideir@gtlaw.com

Category(s): Florida - 09/27/2017

NCCI Makes Workers’ Compensation Filing for Rate Decrease

On August 28, 2017, the National Council on Compensation Insurance (“NCCI”) submitted a filing to the Florida Office of Insurance Regulation (“OIR”) in which NCCI recommended an average premium decrease of 9.6 percent, effective January 1, 2018. The proposal comes in the wake of a 14.5 percent rate increase that became effective in December 2016 after the Florida Supreme Court issues two important rulings affecting workers’ compensation insurance. 
 
In Castellanos v. Next Door Company and Westphal v. City of St. Petersburg, the Court declared several provisions of the state’s workers’ compensation statutes unconstitutional, weakening legislative reforms approved in 1994 and 2003 that were intended to curb the system’s growing costs and higher premiums for employers and businesses. The decisions struck down Florida laws that restricted claimants’ attorneys’ fees to a statutory formula tied to the benefits secured by the claimant and limited the recovery of benefits to 104 weeks for temporary total disability (“TTD”). Both decisions were celebrated by claimants’ attorneys, who believed the laws placed an undue burden on their practice and favored insurers.
 
As a result of the Court’s decisions, the NCCI proposed a workers’ compensation rate increase of 19.6 percent. Ultimately, OIR approved a 14.5 percent increase effective December 1, 2016. Jeff Eddinger, senior executive director for NCCI, said Monday that the 14.5 percent increase was designed to address at least through 2017 higher costs associated with the Florida Supreme Court rulings. In contrast, Monday's filing is based on data from two years before the Supreme Court rulings, the most-recent data available.
 
The premium increase resulted in the Florida Senate and House advancing competing measures in the 2017 session. House Bill 7085 would have made a number of reforms, including permitting direct payment of attorneys by claimants, increasing the combined TDD and temporary permanent disability benefits (“TPD”) from 104 to 260 weeks, and closing a benefit gap that was at issue in Westphal. Like the House bill, Senate Bill 1582 permitted deviations from the current statutory attorney fee schedule; however, the maximum hourly rate that could be used to determine the fee would have been $250 per hour, instead of the $150 per hour proposed in the House bill. Despite strong efforts by insurers and the businesses community, neither measure passed.
 
OIR is expected to hold a hearing on the proposal in October. We will continue to monitor developments related to NCCI’s proposal and workers’ compensation in Florida. Should you have any questions, please do not hesitate to contact us.

Richard J. Fidei, Esq. - GREENBERG TRAURIG LLP, (954) 768-8286 , fideir@gtlaw.com

Category(s): Florida - 09/27/2017

OIR Schedules Hearing for Citizens Rate Increase

The Office of Insurance Regulation (“OIR”) has scheduled a hearing on the rate increase proposed by Citizens Property Insurance Corporation (“Citizens”). The requested statewide average rate changes for Citizens’ business in the Coastal Account (“CA”), Commercial Lines Account (“CLA”), and Personal Lines Account (“PLA”) include commercial property, homeowners, mobile homeowners, and dwelling/fire. Outlined below are the proposed rate changes that have been filed with the OIR: 
•	17-16826: +6.7% to Homeowners Multi-Peril (PLA)
•	17-16827: +1.7% to Homeowners Wind Only (CA)
•	17-16966: +5.2% to Property/Personal (Dwelling Fire) (PLA)
•	17-16967: +6.3% to Property/Personal (Dwelling Fire) Wind Only (CA)
•	17-17210: +3.9% to Mobile Homeowners Multi-Peril (PLA)
•	17-17211: +9.8% to Mobile Homeowners Wind Only (CA)
•	17-17409: +7.1% to Mobile Homeowners (Dwelling Fire) (PLA)
•	17-17410: +10.0% to Mobile Homeowners (Dwelling Fire) (CA) 
Currently, there is not a proposed rate change for sinkhole coverage. If approved, the effective date for the CA, CLA, and PLA would be February 1, 2018 for new and renewal business.

Fred E. Karlinsky, Esq. - GREENBERG TRAURIG LLP, (954) 768-8278 , karlinskyf@gtlaw.com

Category(s): Florida - 09/27/2017

Senate President Makes Appointment to Citizens Board

On August 9, 2017, Senate President Joe Negron (R-Stuart) appointed Blake Capps to the Citizens Property Insurance Board of Governors. The appointment takes effect immediately and will expire on July 31, 2020.
 
Capps is a graduate of the University of Florida and Mercer University Law School and is a founding partner at Capps Roofing, Inc. The family-owned roofing company operates in Martin, Palm Beach, and St. Lucie Counties.
 
This appointment comes on the heels of Governor Rick Scott’s appointment of Chris Gardner to the Citizens Board. Gardner, CEO of Hub International Florida in Winter Park, served as the House Speaker appointee to the Citizens Board until it recently expired. Gardner will now serve until July 31, 2019. The Governor also re-appointed two members to the Citizens Board – Jim Holton and Bette Brown.
 
Holton is the owner of Holton Companies, a real estate development company. He received his bachelor’s degree from Stanford University and his law degree from Boston University. His term ends July 31, 2020. Bette Brown, of Tavernier, is an executive of the CenterState Bank in Tavernier. She received her bachelor’s degree from Stetson University. She will serve until March 23, 2020.

Fred E. Karlinsky, Esq. - GREENBERG TRAURIG LLP, (954) 768-8278 , karlinskyf@gtlaw.com

Category(s): Georgia - 09/27/2017

2018 Georgia Insurance Commissioner's Race

In late July 2017, Georgia Insurance Commissioner Republican incumbent Ralph T. Hudgens announced that he will not seek reelection in 2018 for a third term.  On the heels of that announcement, the following individuals have announced their intentions to run for the state-wide Georgia Insurance Commissioner’s office in 2018:

Republicans:
Jay Florence, Georgia Deputy Insurance Commissioner
Jim Beck, General Manager, Georgia Underwriting Association (Georgia's FAIR Plan) and former Georgia Deputy Insurance Commissioner
Shane Mobley, Founder, Southern Sleep Technologies, Inc.
Jim Kingston, Insurance Executive and son of former  U.S. Representative Jack Kingston

Democrats:
Cindy Zeldin, Executive Director, Georgians for a Healthy Future
Tomeka Kimbrough, Insurance Agent

Brian T. Casey, Esq. - LOCKE LORD LLP, (404) 870-4638 , bcasey@lockelord.com
David M. Green, Esq. - LOCKE LORD LLP, (404) 870-4657 , david.green@lockelord.com

Category(s): Georgia - 09/28/2017

DEPARTMENT ISSUES BULLETIN REMINDING SURPLUS LINES BROKERS THAT FEES ARE PROHIBITED IN THE STATE OF GEORGIA

On September 27, 2017, The Department of Insurance issued Bulletin 17-EX-1 which applies to all insurance companies, brokers and agents selling, soliciting or negotiating surplus lines insurance in Georgia.  The Bulletin reminds surplus lines brokers that they are prohibited from charging customers added fees in excess of the amount of premium shown on a surplus lines insurance policy.  

The Department has stated that collecting fees in excess of the monies specified in the policy are considered an unfair method of competition and an unfair and deceptive act or practice in the insurance business and is a violation of the Georgia Unfair Trade Practices Act.  The Commissioner can impose a monetary penalty of up to $5,000.00 for every act or violation of the Georgia Unfair Trade Practices Act.

Tony Roehl, Esq. - MORRIS, MANNING & MARTIN, LLP, (404) 495-8477 , troehl@mmmlaw.com

Category(s): Georgia - 09/27/2017

Department Issues Directive Clarifying the Obligations of Insurers Offering Hospital Indemnity and Other Fixed Indemnity Coverage

On August 22, 2017, The Georgia Department of Insurance issued Directive 17-EX-5 which withdraws and replaces Directive 15-EX-2 originally issued on January 29, 2015.  On October 14, 2016, the United States District Court for the District of Columbia issued an order in Central United Life Insurance Co. v. Burwell declaring that individual market fixed indemnity plans could be sold and issued regardless of whether the policyholder had purchased minimum essential coverage.  Other requirements applicable to fixed indemnity plans remain intact.  

The Directive lists the three requirements for individual fixed indemnity plans to qualify as excepted benefits:  (1) no coordination with health coverage; (2) benefits are paid on a fixed dollar amount per service on visit; and (3) a required notice on the application materials.  The Directive does not apply to any other type or category of insurance that is listed separately as excepted benefits in the federal Public Health Service Act, i.e., disability income, accident insurance, etc. regardless of whether benefits under such coverage are paid as a fixed dollar amount.

Tony Roehl, Esq. - MORRIS, MANNING & MARTIN, LLP, (404) 495-8477 , troehl@mmmlaw.com

Category(s): Georgia - 09/27/2017

Department Issues Directive for Leniency for Georgia Residents Making Premium Payments in the Wake of Hurricane Irma

On September 10, 2017, The Georgia Department of Insurance issued Directive 17-EX-7 calls for leniency for Georgia residents making premium payments after Hurricane Irma.  Hurricane Irma caused extensive property damage, injuries and several deaths throughout Georgia.  As a result of the storm, millions of Georgia residents lost power and many have yet to have it restored.  On September 10, 2017, Governor Deal issued a State of Emergency for all counties which remained in effect until September 17, 2017.  

The Georgia Department of Insurance encourages insurers to provide relief to policyholders, exercising leniency where premium payments may appear tardy due to the disruption of services caused by the storm.  Insurers processing lawful cancellations or non-renewals during this period are encouraged to ensure that policyholders impacted have sufficient time to address their insurance needs.

Tony Roehl, Esq. - MORRIS, MANNING & MARTIN, LLP, (404) 495-8477 , troehl@mmmlaw.com

Category(s): Georgia - 09/27/2017

Georgia Case Updates

•	American Safety Indemnity Co. v. Sto Corp., Civil Case A17A0453 (Ga. App. 6/30/2017, 8/3/2017)
On August 8, 2017 the Court of Appeals of Georgia reversed the denial of summary judgment to American Safety Indemnity Company (“ASIC”) on the insured’s bad faith claims arising out of ASIC’s refusal to indemnify and defend the insured for two suits against it, because the insurer had a reasonable factual and legal basis for denying coverage.  Sto Corp (“Sto”) filed suit against ASIC asserting breach of contract, declaratory judgment, and bad faith claims arising from ASIC’s refusal to defend Sto for claims related to stucco products that Sto had supplied to certain construction projects. Although the Court of Appeals of Georgia affirmed the grant of summary judgment to Sto on its contract and declaratory judgment claims and finding that ASIC was estopped from denying coverage to Sto, the Court found that the trial court erred in denying summary judgment to ASIC on Sto’s bad faith claim.  The Court of Appeals of Georgia reasoned that in spite of the fact that ASIC was estopped from actually denying coverage, it had reasonable factual and legal basis for denying Sto’s claims at that time and was therefore entitled to summary judgment under O.C.G.A. §33-4-6.  

•	Allstate Property and Casualty Ins. Co. v. Musgrove, (Ga. App. 2017)
On August 24, 2017 the Court of Appeals of Georgia reversed the trial court’s grant of summary judgment and denying summary judgment to an insurer in plaintiffs wrongful death suit following a car accident, because the evidence showed that the decedents had a single automobile insurance policy with $500,000 in uninsured motorist coverage, which the insured  had already paid, rather than two separate insurance policies each providing $500,000 in uninsured motorist coverage. Russell Musgrove and Jeffery Musgrove (the “Musgroves”) insured five (5) vehicles with Allstate under two different policy numbers.  The Musgroves had purchased uninsured motorist coverage with limits of $250,00 per person/$500,000 per accident.  The uninsured motorist coverage was charged under one policy number.  The Musgroves were killed in an automobile accident and Allstate tendered $250,000 on behalf of each Musgrove for a total of $500,000.  The Musgroves’ estate filed suit against Allstate alleging that the Musgroves had two separate insurance policies, each with uninsured motorist coverage and were entitled to additional payments from Allstate.

Allstate presented evidence that despite two policy numbers, the policy declarations were unambiguous and that the uninsured motorist policy premium had only been charged to one policy.  Allstate presented further evidence that the reason two policy numbers were used was that the Musgroves insured five (5) vehicles and the Allstate policy system would only allow four (4) vehicles per policy.  Allstate had also clearly conveyed to the Musgroves that although they were receiving more than one policy declarations page because they were insuring more than four (4) vehicles, there was only a single Allstate insurance policy.  The Court of Appeals agreed with Allstate ruling that the extrinsic evidence presented by Allstate resolved any ambiguity as to whether there was one or two policies and Allstate was entitled to summary judgment.

•	Performance Auto Collision Center Inc. v. Bridgefield Casualty Ins. Co., Civil Case A17A104 (Ga. App. 8/10/2017, 8/29/2017)
On August 10, 2017, the Court of Appeals of Georgia reversed the trial court grant of summary judgment to an insurer and ruled that the classification of employees of an automobile collision center as determined pursuant to workers compensation insurance premium audit was matter for determination by a jury.  Performance Auto Collision Center, Inc. (“PAC”) was insured under a workers compensation insurance policy by Bridgefield Casualty Insurance Company (“Bridgefield”).  At the time the policy was issued, PAC’s employees were classified under two separate classifications, clerical and auto body painting and repair.  The final premium audit conducted by Bridgfield determined that all of PAC’s employees should be classified as auto body painting and repair and that additional premium from PAC was due.

PAC contested the findings of Bridgefield’s final premium audit and Bridgefield filed suit to collect the additional amounts allegedly due as a result of the final premium audit.  Bridgefield filed a motion for summary judgment based on the final audit and classification report conducted by the National Council on Compensation Insurance (“NCCI”) which concluded that all PAC’s employees should be classified as auto body painting and repair.  PAC opposed the motion and presented evidence of a premium audit conducted by another insurer for a different workers compensation insurance policy and additional evidence from PAC’s employees about their duties and locations.  The trial court granted Bridgefield’s motion for summary judgment; however, the Court of Appeals of Georgia reversed, ruling that the correct classification of PAC’s employees was one of fact for a jury to determine.

Brian T. Casey, Esq. - LOCKE LORD LLP, (404) 870-4638 , bcasey@lockelord.com
David M. Green, Esq. - LOCKE LORD LLP, (404) 870-4657 , david.green@lockelord.com

Category(s): Georgia - 09/27/2017

Georgia Insurance Commissioner Hospital & Fixed Indemnity Insurance Policies Directive

On August 22, 2017, the Georgia Insurance Commissioner issued Directive 17-EX-5, which withdraws and replaces Directive 15-EX-2 related to the treatment of individual hospital and fixed indemnity insurance policies as excepted benefits and the required attestation of a consumer applicant for these types of policies that he or she has purchased minimum essential coverage for purposes of Section 5000A(f) of the Internal Revenue Code.  In light of Central United Life Ins. Co. v. Burwell, (D.C., DC 2016), which held that this federally required attestation was unenforceable, Directive 17-EX-5 clarifies that individual hospital and fixed indemnity insurance policies qualify as excepted benefits if (1) there is no coordination between benefits provided under these policies with an exclusion of benefits under any other health coverage, (2) benefits provided under these policies are paid in a fixed dollar amount per period of hospitalization, illness or service and (3), for these policies issued on or after January 1, 2015, required notice of their supplemental nature must be stated in the application for insurance.

Brian T. Casey, Esq. - LOCKE LORD LLP, (404) 870-4638 , bcasey@lockelord.com
David M. Green, Esq. - LOCKE LORD LLP, (404) 870-4657 , david.green@lockelord.com

Category(s): Louisiana - 09/27/2017

Louisiana Update

On the heels of Hurricane Harvey affecting southwestern Louisiana, the Louisiana Department of Insurance has issued Bulletin No. 2017-07.  The purpose of this Bulletin is to remind all insurers authorized to issue vehicle insurance that La. R.S. 32:707.3 provides the proper procedure for obtaining a Certificate of Destruction for water-damaged vehicles.  The Bulletin emphasizes that a water-damaged vehicle is "any vehicle whose power train, computer, or electrical system has been damaged by flooding and that is a 'total loss.'"  Under Louisiana law, a "total loss" is defined as "a motor vehicle which has sustained damages equivalent to seventy-five percent or more of the market-value as determined by the most current National Automobile Dealers Association Handbook."

Van R. Mayhall, III, Esq. - BREAZEALE, SACHSE & WILSON, L.L.P., (225) 381-3169 , van.mayhall.iii@bswllp.com
Van R. Mayhall, Jr., Esq. - BREAZEALE, SACHSE & WILSON, L.L.P., (225) 381-8009 , van.mayhall.jr@bswllp.com

Category(s): New Mexico - 09/27/2017

New Mexico Update

The New Mexico Attorney General, Hector Balderas (D), has filed suit against one of New Mexico's large health insurers for allegedly failing to pay premium taxes.  The lawsuit was filed against Presbyterian Insurance Company, and the lawsuit also includes allegations that the company falsified Medicaid deductions.  The complaint alleges the health system realized “a multimillion-dollar windfall” by evading taxes and surcharges owed on Medicaid premiums from 2001 to 2015.  Among the allegations, the state contends Presbyterian claimed more than $754 million in unlawful deductions for calendar years 2001 through 2011.  Presbyterian has denied the allegations in the complaint, and it maintains that it has fully paid its premium tax obligations.

Gary Kilpatric, Esq. - MONTGOMERY & ANDREWS, P.A., (505) 982-3873 , gkilpatric@montand.com
J. Brent Moore, Esq. - Montgomery & Andrews, (505) 986-2648 , bmoore@montand.com

Category(s): Tennessee - 09/27/2017

TDCI Finalizes Amendment to Minimum Reserve Standards for A&H Policies

A final amendment to Tennessee Department of Commerce and Insurance Regulation 69 (Chapter 0780-01-69) – Minimum Reserve Standards for Individual and Group Health Insurance Contracts – has been approved by the Tennessee Secretary of State and will become effective on October 5, 2017.  The final amendment, which applies to calculation of reserves for health insurance policies as of January, 1, 2017, was the subject of a rulemaking hearing on June 8, 2017.

T. Stephen C. Taylor, Esq. - BASS, BERRY & SIMS, PLC, (615) 742-7758 , staylor@bassberry.com
Robins H. Ledyard, Esq. - BASS, BERRY & SIMS, PLC, (615) 742-6259 , rledyard@bassberry.com

Category(s): Tennessee - 09/27/2017

TDCI to Hold Public Meeting on ACA Exchange Plans

The Tennessee Department of Commerce and Insurance has invited insurance carriers offering plans on the federally facilitated marketplace for the State of Tennessee to overview their plans at a public meeting on October 5, 2017 from 10am to 12pm.  Carriers expected to present at the meeting are BlueCross BlueShield of Tennessee, Cigna, and Oscar.

T. Stephen C. Taylor, Esq. - BASS, BERRY & SIMS, PLC, (615) 742-7758 , staylor@bassberry.com
Robins H. Ledyard, Esq. - BASS, BERRY & SIMS, PLC, (615) 742-6259 , rledyard@bassberry.com

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