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The Department of Financial Services (DFS) posted a reminder to its website about early renewals that are not allowed. DFS is concerned that some small groups in New York may seek to renew health insurance coverage in 2013 that would otherwise not renew until 2014 in order to avoid the requirements of the ACA that take effect on Jan. 1, 2014.

Due to guidance received from the NY DFS, UHC will be requiring and monitoring the following regarding off-cycle changes.

·         New Off-cycle buy down rules

o   Groups can only buy down for financial hardship
o   Group must not be within 90 days of their renewal
o   All requesting groups will required to complete and sign an attestation form stating that they are not changing their plan to solely avoid the impacts of ACA

·         Terming and re-writing groups with UHC/Oxford

o   There must be a 30 day gap in coverage between the term date and new effective date