Weekly Tip: New LTC Advertising Submission Requirement

 

Weekly Tips

New LTC Advertising Submission Requirement

8/13/2014

You may have noticed a few changes with regard to Submission Requirements in the last week.  The Insurance Compact has initiated a new Submission Requirement under Supporting Documentation for all Long-Term Care (LTC) advertising submissions. The new Submission Requirement has two parts. 

The first part is asking that the filer reference the SERFF tracking numbers and the State (IIPRC) tracking numbers for the applicable LTC policy form filings that the advertisements will be used with.  The Associated Filings enhancement that was just included in the August 1st release of SERFF should indicate all the associated LTC filings.  

The second part is asking that the filer identify the type of each advertisement – whether it is “Institutional”, “Invitation to Inquire”, or “Invitation to Contract”.  The review of the advertising submission is determined by the type of advertisement as the Uniform Standards do have specific requirements that are applicable depending on the type of advertisement submitted. 

Remember the original advertising filing must be reopened and the new forms added to the filing (filers that submit a new filing for additional advertising will be asked to withdraw the new submission and reopen the original filing). A Note to Reviewer needs to be sent in the closed filing asking that the closed-approved filing be re-opened so that the new forms may be attached.  Details regarding this particular process may be found in Filing Information Notice 2013-2: Individual Long-Term Care Filings.   

For combination long-term care riders, filers must utilize the LTC TOIs even if the filing includes individual life or annuity policy forms.  By using the LTC TOI, the appropriate Submission Requirements are populated and the Compacting States that have opted out of the individual long-term care Uniform Standards are not included.  

The new Submission Requirement is intended to make the filing process more efficient for both the company filer and the reviewer.  The Submission Requirement is intended to reduce the number of objections issued for these particular filing types.  We hope that this Weekly Tip will improve your filing experience with the Insurance Compact.  If you have any questions regarding this Weekly Tip or filing in general, please contact the Insurance Compact.