Alert Edition January 2017

Welcome to the January 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.

Ryan Smart, Esq., FORC Alert Editor


Category(s): Georgia - 01/25/2017

Georgia Insurance Department Eliminates Annual GLBA Privacy Notice Requirement

Following the trend established by the federal Fixing America's Surface Transportation Act (FAST Act) at the end of 2015 and thereafter by other state insurance departments, the Georgia Insurance Department issued Bulletin 16-EX-2 on November 28, 2016 regarding the ongoing requirement to deliver annual GLBA privacy notices.  This bulletin eliminates the requirement that insurance companies deliver annual GLBA privacy notices if the insurance company has not changed its privacy notice previously delivered to a policyholder and is not required to provide the policyholder with an opt-out right.

Brian T. Casey, Esq. - LOCKE LORD LLP, (404) 870-4638 ,

Category(s): Georgia - 01/25/2017

Georgia Insurance Department Proposes New Regulation for Registration of Rental Preferred Provider Networks

On February 7, 2017, the Georgia Insurance Department will hold a hearing regarding its Proposed Regulation 12-2-44-.11, which will implement the requirement for registration of rented preferred provider networks”.  These preferred provider networks, also referred to as rented or leased networks, are those that contract with a health insurer or other payor or with another preferred provider network to grant access to the terms and conditions of its contract with health care services providers but do not include a proprietary network of a licensed insurer or arrangements providing access to the proprietary provider network of a licensed insurer by its affiliates or by entities receiving administrative services from the licensed insurer or its affiliates.  Georgia Senate Bill 158, which passed last year, established the regulation of rental preferred provider networks.

Brian T. Casey, Esq. - LOCKE LORD LLP, (404) 870-4638 ,

Category(s): Georgia - 01/25/2017

Georgia Issues Bulletin Regarding Senate Bill 302 Provider Directories

On December 8, 2016, the Georgia Department of Insurance issued a new Bulletin (16 EX 3).  The Department reviewed Georgia Senate Bill 302 (“SB 302”) and determined that it is not going to issue any regulations.  The Bulletin also reflects the Department’s current thinking about practical interpretations of SB 302.  The Bulletin does provide some guidance to common questions regarding provider directories.  Importantly, SB 302 does not import the federal requirements for provider directories to insurers who operate outside of the federal exchange.  Insurers can satisfy the annual audit requirement for accuracy of its directory by showing to the Department that it provided a reasonable work effort.  Insurers are required to disclose any tiering they use (linked to reimbursement levels, cost sharing, provider access requirements or any combination thereof) in their respective provider directories.

Tony Roehl, Esq. - BAKER HOSTETLER LLP, (404) 256-8419 ,

Category(s): Illinois - 01/25/2017

Illinois Update

On December 23, 2016, Illinois Governor Bruce Rauner issued a press release stating that Acting Director Anne Melissa Dowling would be stepping down and replaced by Jennifer Hammer.  Please click here to view the press release.

Daniel A. Cotter, Esq. - Dickinson Wright PLLC, (312) 423-8170 ,

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