Around the PIA Western Alliance States – Week of November 13, 2023

Idaho — Open Enrollment for 2024 health insurance is open through December 15, 2023: The open enrollment deadline for Idahoans purchasing or changing their individual health coverage for 2024 is December 15, 2023. With rates for health insurance decreasing on average for 2024, Idahoans are encouraged to make sure they are taking full advantage of all the cost savings available to them, making coverage even more affordable.

Idaho consumers have choices from 8 carriers when shopping for individual coverage. In 2024, Select Health, PacificSource Health Plans, Blue Cross of Idaho, Regence Blue Shield of Idaho, Mountain Health CO-OP, Molina Healthcare, Moda Health Plan, and St. Luke’s Health Plan, will offer health plans on Idaho’s exchange, Your Health Idaho. Similarly, 6 carriers will continue offering dental options.

Those seeking coverage can visit the state’s insurance exchange, Your Health Idaho, at, where a total of 154 medical plans and 21 dental plans can be compared and purchased. Many consumers are eligible for assistance covering premiums, out-of-pocket costs, and deductibles when purchasing through Your Health Idaho. Coverage for plans selected during Open Enrollment begins January 1, 2024.

“Open enrollment only happens once a year, from October 15 to December 15. Now is your opportunity to adjust your plan and review it carefully as networks and benefits may have changed,” said Director Dean Cameron. “We recommend consumers contact a licensed insurance agent for help evaluating the various plan options and eligibility for cost-savings.”

Oregon — Wildfire Risk: New Oregon legislation related to wildfire risk contained in Senate Bill 82 and House Bill 2982 is effective January 1, 2024. Insurers have been instructed to get their filings into the Division of Financial Regulation no later than November 15, 2023. We will provide expedited review, but your help in identifying these filings is crucial.

Please indicate in the first SERFF screen that the filing is made to provide compliance with SB 82 and/or HB 2982.

Please direct questions to:

Jan Vitus (property/casualty, title, surety, misc)

Cliff Nolen (property/casualty)

Michael Drummonds (property/casualty)

Carolyn Kalb (property/casualty)

Oregon — Proposed Rulemaking: Alternative Documentation of Loss Under HB 2982 (2023): The Oregon Division of Financial Regulation recently announced the following proposed rulemaking:

Filing Caption: Alternative Documentation of Loss Under HB 2982 (2023)

Adopt Rule: 836-080-0245

Rule Summary: Compliance with ORS 742.053 and reference to the DFR website for a model form used to attest the

total loss of contents of a residence after a major disaster.

Filed: October 26, 2023

Hearing: November 15, 2023, 9:30 a.m.

This is a hybrid meeting conducted in-person and virtually via Microsoft Teams. See Notice of Proposed Rulemaking for Teams meeting instructions.

Last day/time to offer comment: November 22, 2023, 5 p.m.

For more information on this recently adopted rule, please visit the division’s website:

Oregon — All entities offering health benefit plans in Oregon: The Oregon Division of Financial Regulation (DFR) proposes to issue the attached bulletin regarding expectations for health benefit plans under the Oregon Reproductive Health Equity Act (RHEA). 


The purpose of this bulletin is to provide guidance on the director’s expectations for health benefit plans with respect to RHEA. Topics addressed in the proposed bulletin include:

The scope of services that must be covered under RHEA;

RHEA’s prohibition on cost sharing;   

Reasonable medical management under RHEA for services other than contraception and abortion;

Coverage of contraception under RHEA, including therapeutic equivalents and examples of impermissible restrictions;

Coverage of abortion under RHEA.

Public comments requested:

Public comment will be accepted for 4 weeks. Please submit public comment to

Last day for public comment: Monday, December 4, 2023. Comments must be received by 11:59 p.m.

Click here to review proposed bulletin:

Washington — Implementation of SHB 1266 (Chapter 27, Laws of 2023): We adopted the Implementation of SHB 1266 (Chapter 27, Laws of 2023) rule [(R2023-01)] on November 13, 2023. The rule takes effect on December 14, 2023. The Commissioner is adopting rules to amend current Washington Administrative Code’s to align with SHB 1266 (Chapter 27, Laws of 2023), which created a new section in RCW 48.02, and amended RCW 48.15.103, 48.17.170, 48,17,450, and 48.17.475. In doing so, it will clarify for insurance producers which address of record the Commissioner will utilize when communicating with them.                         

For more information, including the adopted rule (CR-103) and the concise explanatory statement, please visit the rule’s webpage.

Washington — Kreidler asks court to uphold cease-and-desist order against insolvent Pennsylvania insurer: Insurance Commissioner Mike Kreidler petitioned the Thurston County Superior Court on Monday to declare his cease-and-desist order against Senior Health Insurance Company of Pennsylvania (SHIP) valid. The order requires SHIP, an insolvent company that sold long-term care insurance policies, to not enforce any premium increases to Washington consumers due to the misleading coverage election packages it mailed in March 2022.

In addition to misrepresenting benefits, SHIP’s election packages did not accurately reflect the company’s financial condition, which violated state law.

“As Washington’s insurance regulator, it’s my duty to look out for policyholders in our state,” Kreidler said. “SHIP is in dire financial straits and offered people benefit options they simply cannot deliver. I’ll request the Washington courts declare the order to cease and desist against the company valid, to stop the implementation of decisions consumers made based on misleading information the company provided.”

Washington — Best Interest Standard Annuities rulemaking (R 2023-05): We adopted the annuity best interest standard regulations (R 2023-05) on Tuesday, November 7, 2023. The rule takes effect on January 1, 2024. This rulemaking aligns the regulations in the Washington Administrative Code with the new provisions provided by Chapter 64, Laws of 2023, and the updated NAIC Model Regulation # 275. This alignment of authorities requires rulemaking to amend training requirements, revise the prior ‘suitability standard’ with the new ‘best interest’ threshold, and update terminology.

For more information, including the adopted rule (CR-103) and the concise explanatory statement, please visit the rule’s webpage.

If you’ve received this message, you do not need to sign up for any other notice to receive updates on this rule.

Washington — 2023 Direct Practices Report: In accordance with RCW 48.150.100, OIC has published the 2023 Direct Practices Report.

Direct practices were authorized by the Washington State Legislature through a law enacted in 2007 (ESSSB 5958) and codified in the Revised Code of Washington (RCW) as Chapter 48.150. No insurance plan is involved unless a patient has separate insurance coverage for more costly medical services. A set monthly fee is charged for all primary care services, regardless of the number of visits or care provided.

OIC is required to annually report to the Legislature “… participation trends, complaints received, voluntary data reported by the direct practices and any necessary modifications to this chapter.” OIC received one complaint from August 2022 to July 2023 that an unregistered direct practice was unresponsive to attempts to bill and contact them. There are 81 direct practices registered in Washington state, which is a net increase of 25 in the last year. Out of all Washington state residents, 0.4% are enrolled with a direct practice, up from 0.31% in 2022.

For more information, including a copy of the report, please visit the to the OIC’s Legislative and Commissioner Reports Website (linked here –

Washington — Kreidler issues $607,000 in fines for violations in October: Insurance Commissioner Mike Kreidler issued fines in October totaling $607,613.35 against insurance companies and insurance producers who violated state insurance laws and regulations.

Insurance companies

AIG Property Casualty Company, Chicago, Ill.; fined $2,000 (order 23-0182).

    AIG used an incorrect rating factor in 49 instances.

Geico Advantage Insurance Company, Omaha, Neb.; fined $5,000 (order 23-0188).

    Geico failed to conduct insurance business under the company’s legal name.

UnitedHealthcare Insurance Company, Hartford, Conn.; fined $500,000 (order 23-0021).

    UnitedHealth failed to demonstrate its compliance with mental health parity laws. The company was fined $500,000 with $250,000 suspended, pending its adherence to a compliance plan.

Unauthorized insurers

Active Network LLC (Plano, Texas); fined $25,000 (order 23-0203).

    Active Network acted as an unauthorized insurer by selling its refund program to 3,922 people in Washington state for a total of $152,455.18. The company was fined $25,000 with $12,500 suspended.

E. Thongin, DMD, PS, et al., Lynnwood, Wash.; fined $15,000 (order 23-0199).

    E. Thongin, DMD, PS, a professional service corporation, and three professional limited liability companies acted as unauthorized insurers and unlicensed discount plan organizations by selling dental membership plans through its practices.

Producers, agents & brokers

Jessica Fukuchi and PCRG Insurance LLC, Riverton, Utah; fined $1,000 (order 23-0158).

    Fukuchi failed to establish adequate accounting records and adequately handle premium funds and failed to implement the required corrective actions after an initial examination.

Long-term care insurance

Note: Insurance agents are required to receive specific long-term care training and continuing education to ensure they have the knowledge to properly sell long-term care products. The legislature requires insurers to share in the responsibility through an annual education verification process.

RiverSource Life Insurance Company, Minneapolis, Minn.; fined $59,613.35 (order 23-0151).

    RiverSource failed to verify that 10 of its insurance producers completed the required long-term care training before they sold long-term care insurance products. The 10 producers sold 17 policies to Washington consumers on behalf of the company and earned $59,613.35 in commissions.

About PIA Western Alliance

The Professional Insurance Agents Western Alliance is a membership organization promoting and enhancing the success of independent agencies seeking to grow, learn and be heard within the industry.


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