Medicare Part D

[MarcusB-MCM]

We have a life insurance company that has runoff lines of life blocks of business. The new owners are planning to apply for and start offering Medicare Part D as a new line of business (2021 and beyond).

Currently filing annual statement life (blue books), so couple of scenarios:
1. Can the Medicare Part D line, once obtained, be filed within the annual statement life blue books as other A&H?

2. If not, would separate annual statements be required for life (runoff business) and health (Medicare Part D)?

3. Is there a combined option out there? Maybe get state of domicile approval to file one or the other but not both?

If anyone has experience with this please let me know
Marcus

[Glenn]

Hello Marcus,
Please note my responses below in RED to your questions:

Currently filing annual statement life (blue books), so couple of scenarios:
1. Can the Medicare Part D line, once obtained, be filed within the annual statement life blue books as other A&H? YES ( but caution: once your Health business is 95% of total - see Health Test General Interrogatory ( GI Part 2, #2) Doesn?t sound like you would have to file Health Annual Statement any time soon ( Orange Book)

2. If not, would separate annual statements be required for life (runoff
business) and health (Medicare Part D)? See response to #1. Same Blue Book until Health is 95% of total business for two consecutive years ( at that point you switch to the Orange Book).

3. Is there a combined option out there? Reported in Blue Book for now under Other Health until you pass Health test and file orange book Maybe get state of domicile approval to file one or the other but not both? Not both . Comes down to the Health test. Two consecutive years
Regards,
Glenn