MD| Maryland Insurance Administration Bulletin 25-17 provides 2026–2027 filing instructions for student health benefit plans, clarifies when an annual SERFF filing is required, incorporates recent Maryland law changes affecting step therapy, preventive services, discretionary clauses, and copay accumulator programs, and reiterates essential health benefit, actuarial value, mental health parity, and rate-filing standards that carriers must meet for compliant student health coverage.
- Annual SERFF filings (TOI H22, Form/Rate) are required by February 2, 2026 if carriers introduce new/amended forms or revise rates; no filing is needed if prior forms and rating methodology remain unchanged but carriers must still ensure ongoing compliance with all federal and state requirements.
- The bulletin highlights 2025 statutory changes effective January 1, 2026 that bar step therapy for insulin and certain cancer drugs, expand preventive service protections, prohibit discretionary clauses across all health product lines, and regulate copay accumulator treatment of prescription drug cost‑sharing.
- Student health plans must continue to provide individual-market essential health benefits based on Maryland’s 2017 benchmark plan, follow Bulletin 15-33 (as modified by anti-discrimination guidance in Bulletin 23-5), and include Rx benefit certifications that align with 45 CFR § 156.122 and CMS EHB Rx crosswalk methodology.
- Form and rate filings must support variable cost-sharing designs with at least 60% actuarial value, demonstrate MHPAEA compliance for mental health/substance use benefits, and for rate changes include ACA-compliant rating factors, an MLR of at least 80%, AV certifications using the HHS AV calculator, and related documentation.