The Iowa Insurance Division (“Division”) has recently issued Commissioner Bulletin 25-05 regarding the enforcement of Short-Term Limited Duration Plans. The key highlights are as follows:
- In September 2024, the federal government changed the allowable duration of short-term limited duration (“STLD”) plans from up to three years to a maximum of four months. On August 7, 2025, the federal government announced it will not “prioritize enforcement actions” against states that apply the “state law definition of STLD insurance.”
- This means authorized carriers may sell STLD insurance for the duration allowed under Iowa’s regulations
- Under IAC 191-36.4(17), “Short-term limited-duration insurance” means health coverage provided pursuant to a contract with an issuer that has an expiration date specified in the contract that is less than 12 months after the original effective date of the contract and, taking into account renewals or extensions, has a duration of no longer than 36 months in total.
- The Division will allow authorized carriers to sell STLD plans with an initial term of up to 12 months, with renewals permitted to extend the total coverage period up to 36 months.
- Carriers that have not already received the Division’s approval to sell these plans through the SERFF filing process must seek prior approval through this process.
Please note that Commissioner Bulletin 25-05 became effective upon issuance on August 27, 2025.
For any questions related to the above referenced bulletin in Iowa, please contact Westmont Associates!