Alert Edition November 2019

Welcome to the November 2019 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

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Category(s): Alabama - 11/08/2019

Notice of Rate Hearing

A public hearing on proposed revisions of voluntary loss costs and rating values and assigned risk rates and rating values for workers compensation insurance as filed and requested by the National Council on Compensation Insurance, Inc. [“NCCI”], with a proposed effective date of March 1, 2020, will commence at 10:00 a.m. Central Time on Wednesday, November 20, 2019, before the Commissioner of Insurance or his designee in the offices of the Alabama Department of Insurance, RSA Tower Suite 502, 201 Monroe Street, Montgomery, Alabama. 

The filing proposes an overall average decrease of 3.4% to the current voluntary loss cost level and an overall average decrease of 11.5% to the current assigned risk rate level. 

Any persons so desiring may submit a written statement in favor of or against the proposed rating levels and, in addition, may appear and/or make a sworn oral statement at the hearing. Written statements may be directed to the Department’s counsel identified below. Written statements must be received before Wednesday, November 6, 2019. 

Failure of a representative of NCCI to be present at the hearing may result in denial of the requested relief. 
NCCI is advised that the hearing will be transcribed by a court reporter and that the NCCI is responsible for reimbursing the Department of Insurance for the reporter’s appearance fee and cost of preparing the transcript, including reproduction of exhibits.

Stephen W. Still, Esq. - BALCH & BINGHAM LLP, (205) 488-5512 ,

Category(s): Connecticut - 11/08/2019

Connecticut Creates High Deductible Health Plan Task Force

While proposed legislation in Connecticut to lessen the burden of high deductible health plans did not pass, the Connecticut Legislature did create the High Deductible Health Plan Task Force to further explore the structure of high deductible health plans and the impact of such plans on enrollees in Connecticut. On October 17th the Universal Health Care Foundation of Connecticut reported several different statistics to the High Deductible Health Plan Task Force including that “[a] 2019 Benchmark Employer Health Benefits Survey (released by Kaiser Family Foundation) reports a 162% increase in deductible costs in the past ten years.” While this increase in high deductible plans may be decreasing costs, the report noted that these nonetheless decrease care. 
We will continue to watch this task force and report on any real-life solutions it proposes for the people in Connecticut.

Alan J. Levin, Esq. - LOCKE LORD LLP, (212) 912-2777 ,

Category(s): Florida - 11/18/2019

Commissioner Issues Order on Rate Filing

On October 24, Florida Insurance Commissioner David Altmaier issued a press statement on an Order on Rate Filing to the National Council on Compensation Insurance (NCCI) requesting an amended filing to reduce workers’ compensation rates by 7.5 percent for 2020. The Order notifies NCCI that the rate filing submitted for a 5.4% rate decrease has been disapproved and, if amended by November 4, 2019, will be approved with the larger workers’ compensation rate decrease. Approval of a revised 7.5 rate decrease is contingent on the amended filing being submitted with changes as stipulated within the Order. If approved by the Office of Insurance Regulation (OIR), the revised rate decrease would become effective on January 1, 2020, for new and renewal business.

Richard J. Fidei, Esq. - GREENBERG TRAURIG LLP, (954) 592-5530

Category(s): Florida - 11/08/2019

DHSMV to Establish Wireless Device Driving Safety Program

The Department of Highway Safety and Motor Vehicles (DHSMV) has proposed a rule to create a new rule chapter establishing standards for approval and administration of Wireless Communication Device Driving Safety Programs. During the 2019 Regular Session, the Florida Legislature enacted section 316.306, Florida Statutes, which prohibits individuals from using wireless, handheld communication devices while operating motor vehicles in certain designated areas. New rules are necessary to establish standards for program approval and administration.

Fred E. Karlinsky, Esq. - GREENBERG TRAURIG, P.A., (954) 768-8278 ,

Category(s): Florida - 11/18/2019

Governor Announces FinTech Priority Initiatives

On September 16, Governor Ron DeSantis announced plans for financial technology (FinTech) priority initiatives.  Governor DeSantis was joined by Chief Financial Officer (CFO) Jimmy Patronis and Department of Economic Opportunity (DEO) Executive Director Ken Lawson.  Future FinTech initiatives include: 1) expediting the review of Florida Job Growth Grant Fund proposals that provide workforce training programs in the financial services industry, with a focus on FinTech skills training, 2) pursuing legislation to create a regulatory sandbox for FinTech companies in Florida, and 3) facilitating consumer-driven innovation through the American Consumer Financial Innovation Network Partnership.  More information is available here.

Richard J. Fidei, Esq. - GREENBERG TRAURIG LLP, (954) 592-5530

Category(s): Florida - 11/18/2019

Governor Appoints Eight to Cybersecurity Task Force

On September 30, Governor Ron DeSantis announced the appointment of Jeanette Nuñez (Florida’s Lieutenant Governor) as chair to the Florida Cybersecurity Task Force, as well as the appointments of Ben Miron, Linda Reid, Dr. Eman el-Sheikh, Jason Raymond, Bernard Kelly, Michael Delgado and Jeffrey Sturman to the Florida Cybersecurity Task Force.  The task force is charged with: reviewing and assessing the state’s cybersecurity infrastructure, governance and operations; analyzing and identifying potential improvements of state government cybersecurity programs, including individual state agencies; and prioritizing the risks posed by identified threats.

Fred E. Karlinsky, Esq. - GREENBERG TRAURIG, P.A., (954) 768-8278 ,

Category(s): Florida - 11/18/2019

Governor Launches First-of-its-Kind Disaster Mitigation Funding

On October 17, Governor Ron DeSantis announced the launch of the state of Florida’s coordinated effort to access more than $633 million in first-of-its-kind federal funding for disaster mitigation projects. These funds are available through the U.S. Department of Housing and Urban Development’s (HUD) newly created Community Development Block Grant – Mitigation (CDBG-MIT) program formed in response to the 2016 and 2017 presidentially declared disasters. The state of Florida will continue to engage with and seek input from local, state and federal partners on their disaster mitigation needs and priorities. In the coming weeks, DEO will announce upcoming regional workshops, additional webinars and other opportunities for community partners to learn more and provide input on the State Action Plan.

Fred E. Karlinsky, Esq. - GREENBERG TRAURIG, P.A., (954) 768-8278 ,

Category(s): Florida - 11/18/2019

OIR Approves Citizens’ Rates and Forms, Reflecting AOB Reform

On September 30, the Office of Insurance Regulation (OIR) approved changes to Citizens’ rates and forms.  These changes reflect the projected savings due to assignment of benefits (AOB) reform announced June 19, 2019.  The new rates apply to new and renewing personal residential policies with effective dates on or after December 1, 2019. The changes are available here.

Richard J. Fidei, Esq. - GREENBERG TRAURIG LLP, (954) 592-5530

Category(s): Florida - 11/18/2019

OIR Releases Hurricane Michael Analysis

On October 10, the Office of Insurance Regulation (OIR) distributed an analysis on the effect Hurricane Michael has had on the state of Florida.  Among other data, the report discusses the number of claims generated as a result of Michael, which made landfall one year ago.  As of September 27, 2019, a total of 149,448 claims have been filed with more than $7.1 billion in estimated insured losses. The report further analyzes the types of claims filed and how many remain open.  A total of 44 data calls have been completed by OIR which reviewed 400 companies.  Further, claims continue to be filed, including 1,571 in the last 90 days.  The press release and full report are available here.

Richard J. Fidei, Esq. - GREENBERG TRAURIG LLP, (954) 592-5530

Category(s): Georgia - 11/08/2019

Georgia District Courts Address Exclusive Remedy Provisions of O.C.G.A §33-4-6 in Bad Faith Actions

In Georgia, bad faith claims brought by a policyholder against an insurer are codified by O.C.G.A. §33-4-6, which specifies the requirements for a policyholder to recover a civil remedy for an insurer's bad faith refusal to pay a valid claim. Specifically, O.C.G.A. §33-4-6 provides:

In the event of a loss which is covered by a policy of insurance and the refusal of the insurer to pay the same within 60 days after a demand has been made by the holder of the policy and a finding has been made that such refusal was in bad faith, the insurer shall be liable to pay such holder, in addition to the loss, not more than 25 percent of the liability of the insurer for the loss and all reasonable attorney's fees for the prosecution of the action against the insurer.

Even though this statutory regime provides a specific route to recovery for attorney's fees and penalty damages in justified situations, plaintiff insureds continually plead for extra-contractual damages outside O.C.G.A. § 33-4-6, such as punitive damages (O.C.G.A. § 51-12-5.1) and damages under general penalty statutes such as O.C.G.A. § 13-6-11.

However, in two 2019 decisions, Georgia federal courts have upheld the exclusive remedy rule for bad faith actions set forth in O.C.G.A. § 33-4-6.   In Maddox v. State Farm Fire and Cas. Co., 2019 WL 137596 *2 (M.D. Ga. Jan. 8, 2019)?, the United States District Court for the Middle District of Georgia struck the plaintiffs claim for damages under O.C.G.A. §33-4-6, because the plaintiffs did not comply with the procedural requirement of a bad faith demand 60 days prior to filing suit.  Additionally, the United States District Court struck plaintiffs' claim for damages under O.C.G.A. §13-6-11, finding that the exclusive remedy for recovering litigation expenses in insurance cases is Ga. Code Ann. § 33-4-6. 

In another 2019 decision, the United States District Court for the Northern District of Georgia awarded summary judgment in favor of the insurer, addressing policyholder's claim for punitive damages, stubborn litigiousness, unnecessary legal expenses and attorney's fees in addition to damages under O.C.G.A. § 33-4-6.  In Sutton v. State Farm Fire and Cas. Co., 2019 WL 2004133 (N.D.Ga. Feb. 26, 2019), the United States District Court for the Northern District of Georgia dismissed the plaintiff's claim for bad faith damages under O.C.G.A. §33-4-6, finding that based upon the information gathered during the insurer's arson investigation, the insurer had reasonable grounds for contesting coverage. The court then dismissed the plaintiff's claim for punitive damages and claim for recovery for stubborn litigiousness ruling that the exclusive remedy for bad faith breach of an insurance contract is set forth in O.C.G.A. §33-4-6.

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

Category(s): Georgia - 11/08/2019

Southern Trust Insurance Company v. Mountain Express Oil Company, Case No. A19A0018 (Ga. Ct. of Appeals June 5, 2019)

The Georgia Court of Appeals recently upheld the trial court’s ruling that an insurer was required to defend any suit, as opposed to any claim in a suit under a commercial insurance policy.

Southern Trust Insurance Company issued a commercial liability insurance policy to Mountain Express. While the policy was in effect, Empire Petroleum sued Mountain Express for breach of contract, libel and slander, and other causes of action. Southern Trust refused coverage to Mountain Express for the entire lawsuit, arguing that the policy did not cover non-libel slander claims. Mountain Express objected to that refusal and retained its own counsel. Southern Trust retained its own attorneys for the libel and slander claims. Southern Trust agreed to pay Mountain Express's attorneys for their libel and slander defense services at the rate it paid the lawyers it had retained. After the Empire lawsuit settled, Mountain Express sought reimbursement of the full amount of its attorneys' fees of approximately $1.2 million from Southern Trust. Southern Trust denied reimbursement for the attorneys’ fees and Mountain Express filed a lawsuit for breach of the insurance contract against Southern Trust.  Each party moved for summary judgment. The trial court granted Mountain Express's motion for summary judgment and denied Southern Trust's cross motion for summary judgment, noting that Southern Trust waived its defenses when it failed to file a declaratory judgment action. Southern Trust appealed, arguing that it had performed its obligations under the insurance contract, that it was not required to file a declaratory judgment action.

The Georgia Court of Appeals rejected Southern Trust's argument, noting that the appeal raised questions of a duty to defend and the propriety of a declaratory action to settle coverage disputes.  The Georgia Court of Appeals determined that the language of the commercial insurance policy required Southern Trust to defend any "suit" and not just any "claim" in a suit. That obligation extended to the entire lawsuit if any of the suit's individual claims could be covered under the policy.  As a result, the Georgia Court of Appeals determined that Southern Trust breached its obligation when it declined to defend the entire lawsuit, ruling that when an insurer refuses to cover the entire lawsuit and the insured objects, the insurer must file a declaratory judgment action to determine the scope of its duty to defend under the insurance policy in question.

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

Category(s): Georgia - 11/08/2019

Wilkinson v. Georgia Farm Bureau Mutual Insurance Company, (Ga. Ct. of Appeals, September 20, 2019

The Georgia Court of Appeals recently ruled that damages related to an auto accident in a residential driveway were covered under a homeowner's insurance policy.  
Barbara Wilkinson was inspecting a pickup truck owned by Paul Buchanan that she was considering purchasing. At the time, the truck was parked in Buchanan’s home’s driveway on an incline. Wilkinson accidentally pulled the emergency brake release and the truck rolled over her ankles, causing her ankle fractures, a broken shoulder, broken tibia and fibula, and a knee injury. Wilkinson sued Buchanan for negligence and other causes of action. Georgia Farm Bureau Insurance Company, Buchanan’s homeowner’s insurer, filed against Wilkinson a complaint for declaratory judgment that enumerated several reasons why the homeowner’s insurance policy it issued to Buchanan did not cover her injuries. Wilkinson counterclaimed, arguing that the claims she raised in a separate civil action were covered under the homeowner's insurance policy. The trial court granted Georgia Farm Bureau’s motion for summary judgment, finding that the truck was "in use" at the time and the homeowner’s insurance policy excluded coverage for injuries arising out of use of a motor vehicle. 
The Georgia Court of Appeals court rejected the trial court's conclusion and determined that Wilkinson's injuries did not arise from the "use" of a motor vehicle. The Georgia Farm Bureau’s homeowner’s insurance policy did not define the phrase "use of a motor vehicle", and the court concluded that "use" does not extend simply to an actual physical contact, and that "use" contemplates some utilization of the truck as a motor vehicle at the time of the injury. The evidence in this case did not demonstrate such "use", but only showed that the truck was being inspected at the time of the accident. It was only parked in a driveway when Wilkinson and her husband were inspecting it. As such, the Georgia Court of Appeals determined the vehicle was not in use at the time of the accident, and the trial court erred in concluding ?that the exclusion in Georgia Farm Bureau’s policy applied to preclude coverage for Wilkinson's injuries.

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

Category(s): Idaho - 11/08/2019

2019 Idaho Legislative Update: Enhanced Short-Term Health Insurance

The 2019 Idaho legislature revised Idaho’s individual health insurance statutes to create a new category of health insurance referred to as “enhanced short-term.” The legislation dovetails with recent federal action to allow non-Affordable Care Act coverage to be renewable for up to 36 months. Under the new Idaho law, any plans that are renewable for more than 12 months must comply with benefit mandates and other consumer protections to be specified in administrative rules of the Department of Insurance. The Department issued its initial rule as a temporary rule that took effect on July 1, 2019. The highlights of that rule include:

1.	Any health insurance coverage in Idaho that has a duration of more than six months (including renewals, extensions, or reissuances) must comply with the requirements for “enhanced short-term” coverage.

2.	Any issuer of enhanced short-term coverage must also issue a qualified health plan on Idaho’s health insurance exchange.

3.	Enhanced short-term coverage is guaranteed issue, meaning no person can be denied a policy due to health status. No variance in premium based on gender is allowed, but medical underwriting is permitted. A healthier person will pay less than a person who has higher medical risk.

4.	Enhanced short-term coverage is guaranteed renewable up to a total of 36 months.

5.	When the limitation on renewal is reached, the carrier must offer the individual the option of reapplying for enhanced short-term or enrolling in fully renewable coverage.

6.	A carrier cannot increase the premium of an individual upon reapplication by more than 15% for reasons related to adverse claims experience.

7.	Enhanced short-term coverage counts as qualifying prior coverage, so pre-existing condition exclusions must be waived for the period-of-time a person had enhanced short-term coverage.

8.	Carriers can choose to offer enhanced-short term on a year-round basis, in which case the carrier can impose a six-month waiting period on coverage for preexisting conditions. Or carriers can choose to offer enhanced short-term during the open enrollment period for qualified health plans, in which case the carrier cannot impose waiting periods for preexisting conditions.

9.	Enhanced short-term coverage must cover at least: outpatient services, emergency care, hospitalization, maternity and newborn care, mental health and substance abuse disorder services, prescription drugs, rehabilitation treatment, laboratory services, and preventative care.

10.	The drug formulary must include at least one drug in each USP category and class, cover a range of drugs across a broad distribution of categories, classes, and treatment regimens, provide appropriate access to drugs in accordance with best practices.

11.	Coinsurance cannot exceed 50% of covered charges, and the maximum out-of-pocket cannot exceed 4% of the aggregate annual limit on benefits.

12.	The policy can have an annual limit on benefits that is not less than $1 million.

Gabriel Hamilton, Esq. - Holland & Hart LLP, (208) 383-3952 ,

Category(s): Indiana - 11/08/2019

Indiana Department of Insurance Implementing the FAST Act

The Indiana Department of Insurance adopted changes to 760 IAC 1-67-4 ( formally implementing the FAST Act provisions added to the Gramm-Leach-Bliley Act.  Effective October 19, 2019, insurers who (1) provide nonpublic personal information to nonaffiliated third parties only in accordance with specified provisions of the rule and (2) have not changed their policies and practices with regard to disclosing nonpublic personal information from the policies and practices that were disclosed in the most recent disclosure sent to consumers are not required to provide an annual disclosure as required by the rule until one of the above provisions has changed.

William O. Williams II, Esq. - Frost Brown Todd LLC, (317) 237-3815 ,

Category(s): Kansas - 11/08/2019

Kansas Attorney General Issues Opinion Regarding Scope of Kansas Insurance Department’s Regulatory Authority

On September 9, the Kansas Attorney General (AG) issued Opinion NO. 2019-7 stating that the Kansas Insurance Department (KID) lacks authority to deny an application for licensure or registration as a Utilization Review Organization (URO), Pharmacy Benefits Manager (PBM), or Third Party Administrator (TPA) when the applicant exhibits certain words in its name that are restricted for use only by entities that are licensed under the Kansas Pharmacy Act (e.g. Rx or pharmacy) and the applicant is not so licensed. The AG reasoned that the KID lacks such authority because the statutes that set forth the permissible grounds for denying an application for licensure or registration as a URO, PBM, or TPA do not expressly reference the foregoing situation.  
The AG also refused to address two additional questions:  (1) to what extent a URO, PBM, or TPA may use or exhibit the restricted wording if the entity is not licensed under the Kansas Pharmacy Act, and (2) whether the phrase “or other place” as used in K.S.A. 2019 Supp. 65-1626(xx) includes certain nonphysical locations.  The AG opined that those questions “are not within the jurisdiction of the KID and any violation of [the relevant] statutes is dependent upon facts determined by the appropriate agency having jurisdiction.”

Jennifer L. Osborn, Esq. - Polsinelli PC, (913) 234-7472 ,
Steve Imber, Esq. - POLSINELLI, P.C., (913) 234-7469 ,

Category(s): NAIC - 11/20/2019

NAIC tackles Artificial Intelligence

The NAIC’s Artificial Intelligence Working Group is developing broad principles to guide the use of artificial intelligence by the insurance industry and will start with general principles adopted by the OECD.  Commissioner Godfread (Chair - ND) hopes to have the group's insurance-specific principles ready for adoption by the Executive Committee at the NAIC's summer 2020 national meeting.  If you’d like to hear Commissioner Godfread’s thoughts about A.I., check out this recent interview.  Among other things, he discusses what insurers can and should be doing to protect consumers right now, even before regulatory guidance is finalized.

Scott M. Kosnoff, Esq. - FAEGRE DRINKER, (317) 237-1201 ,

Category(s): New York - 11/08/2019

NYDFS Became the First State Insurance Regulator to Implement a ‘Best Interest’ Standard

Suitability Standard: NYDFS became the first state insurance regulator to implement a ‘best interest’ standard that requires sellers of annuities and life insurance to act in the best interest of consumers when providing recommendations.  Now, following an Article 78 proceeding by the three largest trade groups representing New York's insurance producers,  being the Independent Agents and Brokers of New York, Inc., the Independent Insurance Agents and Brokers of New York and the Professional Insurance Agents of New York State, Inc., which sought a ruling by the New York State Supreme Court to invalidate the regulatory action by the New York Superintendent of DFS  promulgating the ‘best interest’ standard as "arbitrary and capricious", the Court has rejected such  allegations. As a result, the discretion of the Superintendent to promulgate the new regulation, in the best interests of insurance consumers, was upheld.   In a press release dated August 3, 2019, DFS Superintendent Linda Lacewell stated that "[T]his is a common-sense regulation and it is a step in the right direction to protect consumers by ensuring that only consumers’ needs and financial objectives are considered in any transaction.”

Frederick J. Pomerantz, Esq. - INSURANCE LEGAL & REGULATORY CONSULTING, PLLC, (516) 297-3101 ,

Category(s): New York - 11/08/2019

Pending 54th Amendment to Insurance Regulation 62, 11 NYCRR 52, Section 52.1(s)

Female Reproductive Rights: Pending 54th Amendment to Insurance Regulation 62, 11 NYCRR 52, Section 52.1(s), was added to incorporate New York State policy to protect women’s access to comprehensive and affordable contraception. One of the greatest impediments to gender equality is the inability to make justified reproductive health decisions or decide when and whether to become a parent. Contraception has been a critical tool for women to gain economic and social independence. The use, accessibility, and availability of contraception also reduces the rate of unintended pregnancy and abortion. 

Irrespective of whether the federal government rolls back access to reproductive health care, the State of New York will protect women’s unassailable right to their reproductive freedom. Chapter 25 of the Laws of 2019 and Part M of Chapter 57 of the Laws of 2019 has amended Insurance Law sections 3216(i)(17)(E), 3221(l)(16), and 4303(cc) to require every policy that provides medical, major medical, or similar comprehensive type coverage to provide broad contraceptive coverage. Chapter 25 also requires the superintendent to promulgate regulations establishing a process, including timeframes, for an insured, an insured’s designee, or an insured’s health care provider to request coverage of a non-covered contraceptive drug, device, or product. Section 52.74 of this Part establishes such a process.

Frederick J. Pomerantz, Esq. - INSURANCE LEGAL & REGULATORY CONSULTING, PLLC, (516) 297-3101 ,

Category(s): New York - 11/18/2019

Unauthorized Insurance Activities being Addressed in New York

On September 11, 2019, the New York State Department of Financial Services (“DFS”) issued Insurance Circular Letter No. 10 (2019), addressing unauthorized insurance activities in New York related to group annuity contracts and pension risk transfer transactions.  Circular Letter No. 10 prohibits life insurers not licensed in New York from soliciting, negotiating, selling and servicing group annuity contracts and from receiving premiums and other fees in New York, and prohibits licensed insurance producers and other persons from aiding these activities or otherwise calling attention to unlicensed insurers in New York.  In addition, the Circular Letter instructs that in New York, a New York-licensed insurer should deliver or issue for delivery and administer all group annuity terminal funding or close-out contracts and certificates that are part of a pension risk transaction involving New York residents.  The Circular Letter emphasizes that the prohibited activities violate New York law and will result in fines and follows the DFS’s earlier comments that it had uncovered widespread violations in the pension risk transfer business and will act against such violations to the full extent of its authority.

Allison J. Tam, Esq. - WILLKIE FARR & GALLAGHER LLP, (212) 728-8282 ,

Category(s): Tennessee - 11/08/2019

Carter Lawrence Elevated to Chief Deputy at TDCI

Shortly after Commissioner Hodgen Mainda’s appointment, he named Carter Lawrence to fill a new position as Chief Deputy and COO of the Tennessee Department of Commerce and Insurance.  Prior to his promotion, Chief Deputy Lawrence was Deputy Commissioner for Regulatory Boards, and served earlier this year as Interim Commissioner of TDCI.

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

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