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March 31, 2020

State Insurance Spotlight: Maryland Insurance Administration Guidance Concerning COVID-19

State insurance departments across the country are continuing to provide guidance in response to the COVID-19 outbreak. In this update, Faegre Drinker spotlights the current Maryland Insurance Administration (MIA) guidance with respect to COVID-19 issues.

MIA Bulletins

Bulletin 20-16: Conducting Mobile Settlements (March 30, 2020)

  • Permitting, during the state of emergency, licensed title insurance producers to conduct remote settlements so long as the settlement agent follows the guidelines as they are outlined in the governor’s order.

Bulletin 20-15: Commercial Use Exclusion in PPA Policies (March 30, 2020)

  • Strongly encouraging all property and casualty insurers writing private passenger automobile (PPA) liability coverage to follow a “major market share PPA insurer group” that wants to temporarily waive the commercial use exclusion during the COVID-19 emergency; MIA will waive filing fees and will expedite review/approval of filings (within 24 hours of submission, if possible).

Bulletin 20-14: Premium Receivables Over 90 Days During the COVID-19 State of Emergency (March 26, 2020)

  • Providing procedure to obtain a waiver of the Statutory Accounting Principle that requires an insurer to non-admit premium receivable assets over 90 days past due for Maryland-domiciled insurers that give premium grace periods to policyholders under the COVID-19 State of Emergency.

Bulletin 20-13: Temporary Suspension of 45-day Advance Mailing Notice under §§ 27-613 and 27-614 (March 25, 2020)

  • Waiving the required PPA 45-day advance notice of cancellation is suspended, except for cancellations for non-payment of premiums per MIA Bulletin 20-10.

Bulletin 20-12: Property & Casualty Temporary Rate Relief Filings (March 23, 2020)

  • Encouraging property and casualty insurers to provide temporary rate relief to insureds during the COVID-19 emergency; MIA will waive filing fees and provide expedited review for rate relief.

Bulletin 20-11: COVID-19 State of Emergency: Remote Claim Handling (March 23, 2020)

  • Encouraging all licensees to use remote claim handling as much as possible; for on-site claim handling activity, all parties must use social distancing protocols published by the CDC.

Bulletin 20-10: Cancellation of Life & Health and Property & Casualty Insurance Policies and Contracts Due to Non-payment of Premium during the COVID-19 State of Emergency (March 20, 2020)

  • Encouraging insurers to make reasonable accommodations so that individuals and businesses do not lose coverage due to non-payment of premium.

Bulletin 20-09: Travel Insurance Sales During the COVID-19 State of Emergency (March 20, 2020)

  • Requesting that during the COVID-19 emergency, all insurers that issue travel insurance provide an option for consumers to purchase a Cancel for Any Reason waiver for trips cancelled due to COVID-19.

Bulletin 20-08: Scheduling of Title Insurance Producers on Site Reviews (March 16, 2020)

  • Advising that, if a title insurer believes that it is not safe to conduct an on-site review, the audit can be rescheduled for a later date as long as the audit is completed on or before December 31, 2020.

Bulletin 20-07: Healthcare Common Producer Coding System (HCPCS) Code for Certain COVID-19 Diagnostic Tests (March 13, 2020)

  • Advising health insurers that the Center for Medicare & Medicaid Services has developed an HCPCS code for laboratories to use to bill for COVID-19

Bulletin 20-06: COVID-19 Follow Up (March 10, 2020)

  • Requiring all health carriers to:
    • Waive co-payments, coinsurance and deductibles for any visit to diagnose or test for COVID-19.
    • Waive co-payments, coinsurance and deductibles for laboratory fees to diagnose or test for COVID-19.
    • Waive co-payments, coinsurance and deductibles for COVID-19 vaccination (when it becomes available).
    • Evaluate requests for use of an out-of-network provider for diagnostic testing of COVID-19 solely on medical necessity.
    • Expedite grievance procedures for adverse decisions on request for coverage for diagnostic services for COVID-19.

Bulletin 20-05: Emergency Bulletin on COVID-19 (March 6, 2020)

  • Announcing to health carriers that as a result of Governor Hogan’s Proclamation declaring a State of Emergency, the Commissioner is invoking his emergency powers.
    • Encouraging carriers to communicate information to their members regarding insurance coverage and medically necessary health care services regarding COVID-19.
    • Encouraging carriers to review provider panels to ensure members have access to treatment for “severe cases of COVID-19” and plan for out-of-network referrals.
    • Giving an overview of emergency regulations the Commissioner will be promulgating.


Other MIA Information

MIA Presentations

COVID-19 and Maryland Licensed Insurance Professionals: What You Need to Know (March 25, 2020)

  • Recording of WebEx meeting for licensed insurance professionals held by the MIA regarding the impact of the COVID-19 pandemic, including operational update, resources available to licensed insurance professionals and their clients, MIA’s role during the pandemic, an overview of regulatory actions already taken, and a Q&A session.

Additional Information

For additional Maryland COVID-19 information, please visit:

The material contained in this communication is informational, general in nature and does not constitute legal advice. The material contained in this communication should not be relied upon or used without consulting a lawyer to consider your specific circumstances. This communication was published on the date specified and may not include any changes in the topics, laws, rules or regulations covered. Receipt of this communication does not establish an attorney-client relationship. In some jurisdictions, this communication may be considered attorney advertising.

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