News

Today is the due date in the Uniform Standards for LTC filers to submit annual certifications for Compact-approved rate schedules, including triennial actuarial memoranda where applicable. This due date snuck up on the Compact Office and likely several LTC filing companies amid the transition to the new SERFF platform. Thank you to those filers who have already taken care of this requirement.

The due date is now extended to May 16, 2025, for any annual certification and applicable triennial memorandum (as well as projections due for in-force rate increases approved by the Compact). The filer does not need to notify the Compact Office unless a further extension is needed, in which case please submit a Note to Reviewer in the applicable SERFF filing(s).
Section 3B of the Rate Filing Standards for Individual Long-Term Care Insurance contains the filing requirements. The certification(s) should reflect cumulative experience as of year-end 2024. Additionally, checklists for the annual certification and, if applicable, the triennial memorandum submissions can be found on the Compact’s website for IIPRC-LTC-I-3-RATEI on the Overview tab.

As you should be aware, all SERFF submissions to the Compact are now made in the new SERFF platform. If the company needs any assistance with making the submission, please contact serffmodernizationquestions@naic.org and use the subject line "LTC Certification Help" and include the SERFF Tracking Number of the applicable filing.

The following is an outline of procedures for filing this certification:
•    Access the SERFF platform using the specific Okta login credentials for the new system.
•    The filing has been automatically reopened with a status of Reopened-Annual Rate Certification. Do not submit a certification in a new SERFF filing.
•    Create an Amendment in SERFF, add the annual certification to the Rate/Rule Schedule tab and, if you wish, add a cover letter to the Additional Supporting Documents tab.
•    No previously submitted or approved items should be withdrawn or removed when the certification is submitted.
•    Include the year 2024 in the Document Name field and the attachment file name.
•    Submit the applicable Compact Filing Fee amount for each rate schedule. The fee is $1,000 for the annual certification for each rate schedule, plus an additional $500 if the supporting triennial actuarial memorandum is due.
•    If there is a trade secret request involving a triennial memorandum, consult FIN 2024-1 for the applicable process. The Compact is not currently using the SERFF functionality for submitting a public access exception request.

We hope this provides you with the information you need to prepare the annual rate certification for submission. Again, for assistance with the SERFF submission, please contact serffmodernizationquestions@naic.org and use the subject line "LTC Certification Help" and include the SERFF Tracking Number of the applicable filing. If further information about the underlying requirements is needed, please contact the Compact Office, comments@insurancecompact.org.