Filing Guidance

Combination Property and Accident & Health Submissions

Combination submissions are usually comprised of travel insurance products containing both Property and Casualty insurance and Accident and Health insurance benefits combined into one policy/certificate.

  • To the extent possible, insurers are strongly encouraged to submit Property and Casualty insurance benefits and Accident and Health insurance benefits in separate forms with separate form numbers. This may be accomplished by having a policy/certificate with some combination of insert pages and/or by having separate riders to be attached to the policy/certificate. The policy/certificate, riders and insert pages should be such that those pertaining to Property and Casualty insurance contain no Accident and Health provisions and the policy/certificate, riders and insert pages that pertain to Accident and Health insurance contains no Property and Casualty insurance provisions. This includes any standard provisions included in the policy forms. In addition, the policy forms submitted to the Health Bureau must be accompanied by the requisite actuarial memorandum and rate manual pages.
  • Policy forms dealing with Property and Casualty insurance should be submitted to the Property Bureau only and the policy forms dealing with Accident and Health insurance should be submitted to the Health Bureau only. To the extent that forms are not separated, please be advised that the Health Bureau will only be reviewing the portions of the form that relate to Accident and Health insurance. When the Accident and Health provisions are acceptable and in compliance with all Accident and Health statutes and regulations, the Health Bureau will approve only those provisions of the form that relate to Accident and Health insurance. The form may not be used until approval of the same form is received from both Bureaus.

    Please be advised that combined application and/or enrollment forms may be used for travel insurance products. Combined application and/or enrollment forms which contain both Accident and Health benefits and Property and Casualty benefits must be submitted to both the Property Bureau and to the Health Bureau for review. Also, any riders, endorsements or revised memoranda of variable material to be used with previously approved combination forms must be submitted to both Bureaus.

  • Each Bureau will send a separate letter to the company. The form may not be used until approval of the same version has been received from both Bureaus.
  • It is the responsibility of the company making the submission to make sure that the same version of the form is approved by both Bureaus. The only

    version of the form that may be used is the version that has been approved by both Bureaus.

  • Insurers are reminded that they should reach out to the Property Bureau and make sure that any separate filing requirements imposed by the Property Bureau are also complied with.