Weekly Tip: New LTC Advertising Submission Process

 

Weekly Tips

New LTC Advertising Submission Process

5/5/2016

On April 29th, 2016 the IIPRC Office announced a new process for long-term care advertising submissions. Filers are now able to make submissions of individual long-term care advertising forms even when previously-filed submissions are pending or undergoing review. This modified process has been implemented on a “pilot” basis through September 1, 2016, at which time the IIPRC Office will determine whether to amend, extend, or make permanent this new process.

The advertising process still requires a single submission per long-term care product approved by the IIPRC. Now, however, company filers are able to submit additional forms for review while the review for previously-filed forms is ongoing. Companies will no longer have to wait for the disposition of previously-submitted forms before adding to their individual long-term care advertising filing. This requires the company filer to submit a single Statement of Variability per form, on an individual schedule item under Supporting Documents. Previously, company filers were submitting a single Statement of Variability per batch of forms. In order to facilitate the review and approval on a per-form basis, the new process requires company filers to include the Form Number that corresponds with the variability in both the PDF file name and the heading on each document. For each new advertising form that has variability, a Statement of Variability should be submitted on a separate line under the “Supporting Documentation” tab.

NOTE: Failure to submit a separate Statement of Variability on separate lines means the filer will have to wait for approval of all the forms for which the Statement of Variability was submitted in batch under one Supporting Documentation tab item.

With this new process, the date of approval may no longer match the date of a Disposition on the Filing Correspondence tab. The date of approval for each form will be indicated in the Schedule Item Status column of the Form Schedule.

The general instructions in the Insurance Compact’s instance in SERFF have been updated to reflect this new filing process. The Filing Information Notice that was issued February 2013 – FIN 2013-2: Individual Long Term Care Filings – has also been updated to include the new process as Appendix A.

The IIPRC Office will be conducting a webinar on this topic at the end of May. Please stay tuned for more details.