

State-by-state variations of laws, compliance protocols, industry transparency, and general regulatory culture can lend one the impression that keeping up with industry changes is a little bit like herding cats. So, what better way to wrangle some of the more localized insurance news than in a Regulatory Roundup?
On an ongoing basis, in no particular order or rank, we’re wrestling the various regulatory changes, compliance actions, and commissioner decisions into our roundup. As a disclaimer: There’s a lot going on at any given time in these here United States, so this isn’t a comprehensive picture of state-level action by any means. Think of it, instead, as a sampler platter of regulation.
Also important to note: If we’re recapping interpretations of legal decisions, this is some armchair insurance speculation and not at all legal advice. If you need legal advice, get a lawyer.
Washington comes down on HCSM that left consumer with $200,000 in medical debt
Commissioner Mike Kreidler announced the state levied a $300,000 fine against a health care sharing ministry (HCSM) after the Office of the Commissioner of Insurance received a consumer complaint.
According to the news release, the complaint was that a member of the HCSM had received medical care they believed was covered as part of their plan, but the HCSM paid only $5,000 toward their care. This left the consumer with nearly $200,000 in unpaid medical bills.
The state alleges the company doesn’t meet Washington’s minimum legal definition of an HCSM, and excludes consumers with pre-existing conditions, which violates the Affordable Care Act. This puts the organization in the unfavorable position of acting as an unauthorized insurer.
“[The business] acted as an unauthorized insurer when it enrolled more than 320 Washington residents in its membership program and collected membership fees. From 2019 to 2023, [the business] collected $2,919,125.19 in membership fees from Washington residents, leaving it with $74,999 in unpaid premium taxes,” the news release said.
Change Healthcare provides HIPAA update in wake of cyberattack
In February, Change Healthcare, which touches millions of consumers across America, suffered a large cyberattack that compromised patient records and shut down pharmacy care and health services across the country.
Now, the company has issued an update on their ongoing investigation into the data breach. The company said it has thoroughly reviewed 90 percent of the impacted records, and celebrated the fact that medical histories and doctors’ offices’ files didn’t seem to be swept up in the breach. However, Change Healthcare confirmed that, for consumers whose data was compromised, that data might include names, birth dates, addresses, emails, Social Security numbers, and other personal identifying information.
Change Healthcare is taking responsibility for notifying everyone impacted, but current or past customers of the business can also proactively seek out resources at https://www.changehealthcare.com/hipaa-substitute-notice.
FINRA adjusting tech to cope with resident location offices
Thanks to some of the adjustments coming out of the COVID-19 pandemic, brokers working remotely filed branch location paperwork with the Financial Industry Regulatory Authority (FINRA). At the time, many oversight and on-premise exams were suspended because, you know, the whole deadly pandemic thing.
As the world recalibrates, however, FINRA revisited branch location oversight and has a new rule governing “residential supervisory locations” – FINRA Rule 3110.19. But for offices that are currently registered as branches and need to change their filing status, compliance is a little dicey.
For now, FINRA’s best advice? “Stay put.” FINRA has issued guidance telling anyone registered as a branch location to just hold at the moment as they change the options for U4 filings to make reporting who and who doesn’t require special oversight somewhat easier. In the meantime, firms that are trying to keep up with compliance will need to maintain internal lists of what locations are truly branch locations and which are essentially remote workers.
Other state regulatory changes
Colorado has extended the deadline for anyone who was disenrolled from the state Medicaid program with the end of the COVID-19 Public Health Emergency. Health insurance seekers now have until Nov. 30, 2024, to enroll through Connect for Health Colorado. Legislative session changes also require state health insurers to cover pediatric acute-onset neuropsychiatric syndrome (PANS), treatment related to living organ donation, and doula services, among others.
Connecticut issued a reminder that consumers can get premium discounts on their boat insurance in exchange for taking a boater safety course. The state has also amended the definition of a small employer to include businesses employing no more than 50 employees. Motor vehicle appraisers and casualty adjusters in Connecticut also have a new license expiration date, which will be every other year on your birth date, with that biennial cycle starting based on the last birthday you had before you got your license.
Delaware insurance carriers developing paid family and medical leave plans to participate in the statewide plan will need the state’s updated codes to submit their required SERFF filings.
Illinois adopted a change to the state health care law that requires carriers to cover over-the-counter contraceptives without requiring a prescription.
Kansas Commissioner Vicki Schmidt released her office’s summer newsletter with many summaries of the state’s insurance-adjacent legislative changes. From new limits for state invoicing on carrier financial exams to new cybersecurity limits for members of the state guaranty association, it’s worth a perusal for anyone doing business in Kansas.
Kentucky adopted PSI as the state’s official vendor for continuing education and prelicensing, effective July 1, 2024.
Lousiana Commissioner Timothy Temple issued a news release expressing his frustration with the state governor’s veto of legislation aimed at lowering auto insurance rates. Temple would like legislators to vote to override the veto in a special session. The legislature also passed a law effective Jan. 1, 2025, that requires carriers to allow for a grace period for a surviving spouse to renew their homeowners’ insurance following the death of their spouse. The state also has a law effective Aug. 1, 2024, that allows someone to form an MGA even if they were involved in an insurer’s insolvency if they have clearance from the commissioner.
Maryland Gov. Wes Moore announced the state’s new initiative, a Health Coverage Assistance Team (H-CAT), which will partner trained staff with consumers who are on the hunt for affordable health coverage to find plans that fit their needs.
Massachusetts requires aspiring life settlement brokers to hold a life insurance license for one year before applying for their life settlement broker line.
Minnesota passed legislation effective July 1, 2025, that requires health insurance carriers to include elective, induced abortions as part of maternity care in health care plans.
Michigan Department of Insurance and Financial Services Director Anita Fox issued a bulletin to remind health insurance producers that swapping consumer plans, agents of record, or coverage for consumers without consent runs afoul of state law and Heath Insurance Marketplace state and federal requirements. TL;DR: DON’T DO IT.
New Mexico Superintendent of Insurance Alice Kane issued an emergency order June 18, 2024, in response to the Salt Fire and South Fork Fire. Kane instructs carriers to hold off on canceling or nonrenewing coverage for nonpayment for 120 days following the order, and for health insurers to waive out-of-network requirements for prescription drugs and other medical needs for those whose homes or businesses are located in the affected areas.
Oklahoma legislators passed a law, effective July 1, 2025, called “Corinne’s law,” that requires health insurers to provide coverage for fertility services for anyone of reproductive age undergoing cancer treatment that could affect their fertility. Covered services could include freezing eggs or sperm in the hopes of protecting future fertility.
Oregon will now allow name changes and DRLP changes via NIPR.
Pennsylvania added pet insurance as a limited line, with provisions for disclosures and producer training.
Vermont added pet licensing regulations effective July 1, 2025. Carriers have to train licensed pet producers on products, including how they should disclose preexisting condition limitations, waiting periods, and the effects of hereditary conditions on coverage to consumers.
Washington has proposed a rule change to make limited line credit insurance part of life, disability, property, or casualty licensing; allow agencies to designate a new DRLP during their license renewal, and to require CE for crop adjusters as well as updating language for clarity and to reflect other rule and legislative changes (such as the legislative removal of prelicensing in 2023). Commissioner Mike Kreidler has also asked insurers to extend the additional living expenses benefit for victims of the Gray and Oregon Road fires, even though many ALEs are reaching the end of their 12-month limits.
Wisconsin released the state list of administrative actions taken against individual licenses, and it’s worth noting that paying your taxes is crucial.
SILA announced one new SILA Fellow recipient, Becky Farthing, and five new SILA Associates: Angela Hayden, Teah Lohman, Candice Maberry, Cassandra Navarro, and Carisa Wells. Congrats!
While these points of interest aren’t comprehensive, our knowledge of insurance producer and variable lines broker license and compliance maintenance is. See how AgentSync can help make you look smarter today; head over to the Compliance Library and wrastle up some state-by-state regulation and more jurisdictional updates.