Comments on Model Regulation 171, Definition of “Pre-Existing Condition”, loss ratios, & Additional Matters

The NAIC Consumer Representatives submitted comments on the Model Regulation to Implement the Supplementary and Short-Term Health Insurance Minimum Standards Model Act (#171). They emphasized the need to update Model 171, which has been delayed for over two years. Key recommendations include a clear definition of “pre-existing condition,” shortening the “look-back” period, and increasing transparency for consumers. They advocate for consistent minimum standards across all plans covered by the model, including short-term and supplemental plans, to simplify regulations and protect consumers. They also stress the importance of addressing disclosures, notices, and loss ratios to ensure comprehensive consumer protection.