TITLE 28.INSURANCE

Part 1. TEXAS DEPARTMENT OF INSURANCE

Chapter 3. LIFE, ACCIDENT AND HEALTH INSURANCE AND ANNUITIES

Subchapter Y. STANDARDS FOR LONG-TERM CARE INSURANCE COVERAGE UNDER INDIVIDUAL AND GROUP POLICIES

28 TAC §§3.3818, 3.3829, 3.3830, 3.3839

The Commissioner of Insurance adopts amendments to §§3.3818, 3.3829, 3.3830, and 3.3839 concerning standards for group and individual long-term care insurance policies and certificates. These sections are adopted with changes to the proposed text as published in the December 3,1999 issue of the Texas Register (24 TexReg 10792).

These amendments address coverage and benefit level criteria, disclosure provisions, application requirements, and standards for marketing. The Commissioner adopts these amendments in response to and after a study of a petition filed by the National Long Term Care Coalition (a group of large employers) and Metropolitan Life Insurance Company for a new benefit level criteria for group long-term care insurance policies and certificates. The individual market was included in the proposal after the department considered pertinent points submitted during the rule formulation process.

The amendments apply to both the group and individual long-term care markets. This gives potential group purchasers similar long-term care product choices in the individual market in addition to what is offered by the group administrator and creates more competition among insurers, thus promoting availability and accessibility of products to all consumers, not just the consumers in the group market.

An insurer or other qualified entity (hereafter referred to as "insurer") that offers long-term care coverage in Texas must use physical and mental standards to determine a covered individual's eligibility for long-term care benefits, services, or coverage. The physical and mental standards used in Texas, and required by federal law, are based on an individual's inability to perform "activities of daily living" (ADL) or "impairment of cognitive ability." Present rules provide that an individual covered under a long-term care policy or certificate qualifies for benefits or services when he or she reaches a state in which the individual cannot perform, without assistance, any two of the following six ADL functions: bathing, continence, dressing, eating, toileting, and transferring. An individual also qualifies for benefits or services under a long-term care policy or certificate if he or she is certified as being cognitively impaired. Cognitive impairment is reached when an individual's intellectual capacity has deteriorated to the point whereby that person requires substantial supervision to protect himself/herself or others. The amendments to §3.3818 allow, under certain circumstances, a new benefit level for long-term care coverage. Under §3.3818, an insurer will be allowed to offer long-term care coverage which provides, in the same policy and/or certificate, benefits based on a covered individual's inability to perform, without assistance, two ADL, three ADL, and cognitive impairment. The insurer may offer such a policy and/or certificate only if all conditions are met.

The amendments require the following safeguards: §3.3818 requires that the agent of the insurer must also offer the two ADL and cognitive impairment policy and obtain a written rejection or acknowledgement of such offer; §3.3829 requires that a long-term care insurance policy and/or certificate which includes a three ADL benefit level shall disclose, within a common location and in equal prominence, a description of benefits payable for two ADL, three ADL, and cognitive impairment; §3.3830 provides that an application for a long-term care policy or certificate containing coverage activated due to an individual's inability to perform three ADL shall reflect, in equal prominence, the benefit levels payable for the inability to perform two ADL, three ADL, and cognitive impairment; and §3.3839 requires that when marketing long-term care coverage containing a three ADL benefit, an insurer provide in the marketing material clear and complete information by disclosing in a common location and in equal prominence benefits payable for two ADL, three ADL, and cognitive impairment.

GENERAL: Some commenters expressed support for the amendments.

AGENCY RESPONSE: The agency appreciates the comments.

GENERAL: A commenter asked for clarification as to whether the amendments would affect a resubmission of a form that included benefits based on three ADL that had been previously filed and disapproved and whether the insurer would be exempt from offering a group policy that provides benefits based on two ADL and cognitive impairment and the written rejection since the plan that would be filed would contain as an integral part, benefits based on two ADL and cognitive impairment. The commenter questioned whether a written rejection of the two ADL and cognitive impairment policy would be necessary.

AGENCY RESPONSE: The adopted amendments will have no effect on a policy filing previously disapproved. The department will consider for approval any future form filing that complies with the adopted amendments and other applicable laws and regulations. If a group two/three ADL and cognitive impairment policy or certificate is offered, a separate two ADL and cognitive impairment policy or certificate must also be offered and a written rejection or acknowledgment of offer of the two ADL and cognitive impairment policy or certificate must be obtained by the insurer or its representative.

GENERAL: Two commenters stated that, if adopted, the amendments should be limited to a group setting. Both commenters are concerned that the adopted amendments would create a greater potential for deception by agents and increase consumer confusion in the individual market. They also suggested testing the effects of the amendments in the group market before introduction into the individual market. One of the commenters also opposed the inclusion of the individual market because this would go beyond the original petition which was the genesis of the amendments and which limited the proposal to group markets.

AGENCY RESPONSE: The department disagrees. The amendments should apply to both group and individual markets to allow all carriers to make more products available to consumers. If the amendments only applied to group markets, the individuals in that market being offered a two/three ADL and cognitive impairment long-term care product through their employer or association would have no similar product in the individual market with which to compare the group product, thus limiting their choices. Extending the amendments to both the group and individual long-term care markets will create more competition among insurers which will create more products and will put consumers in a better position to compare and evaluate the coverage offered and the pricing of the coverage. Although the initial petition addressed groups, after consideration of the petition and the impact limiting the proposal to the group market would have on the marketplace as a whole and the limitations it would place on consumers to adequately evaluate various products, the department decided to include the individual market in the proposed rule to give individuals the opportunity to truly have access to the most appropriately priced and beneficial long term care products.

GENERAL: Two commenters are concerned about the relative value of benefits of the three ADL benefit levels as compared to those of the two ADL and cognitive impairment benefit levels within the two/three ADL and cognitive impairment product as well as the relative value of benefits of the stand-alone two ADL and cognitive impairment product as compared to the two/three ADL and cognitive impairment product. The concern is that an insurer will periodically increase its three ADL benefit levels to reflect the increasing cost of long-term health care while keeping its two ADL benefit levels stagnate. One commenter recommended that the amendments should be changed to "require that payment based on inability to perform two ADL be at least 75% of the benefit based on three ADL." If the department rejects the 75% concept, the commenter proposed alternative language based on a reasonableness standard between the two and three ADL benefit levels.

AGENCY RESPONSE: The department appreciates the commenters' concerns and is committed to preventing an erosion in the differential between two and three ADL benefit levels in the form and rate review process. The department will ensure that unreasonable differentials do not occur between the benefit levels of the stand-alone two ADL and cognitive impairment product, the benefit levels of the two ADL component of the two/three ADL and cognitive impairment product and the benefit levels of the three ADL component of the two/three ADL and cognitive impairment product. The department also reminds the commenter of the provisions of §3.3842 which require that companies and agents make reasonable determinations regarding the appropriateness of the recommended purchase and §3.3820 which requires inflation protection to be offered and if selected will address inflationary concerns.

§§3.3818, 3.3829 & 3.3839: Two commenters expressed concern that adding the three ADL benefit trigger in the two/three ADL and cognitive impairment product will create consumer confusion. This confusion would stem from the fact that consumers will not have enough information to compare the premium and benefit differences between the stand-alone two ADL and cognitive impairment product and the new two/three ADL and cognitive impairment product as well as the differences between the two ADL component as compared to the three ADL component within the two/three and cognitive impairment policy or certificate. One of the commenters suggested that TDI develop a form and require agents to fill in comparisons of the two different products' premium costs, coverages, benefit triggers, and benefits.

AGENCY RESPONSE: In the development of the amendments, the department had concerns about possible consumer confusion. The department addressed those concerns by adding §§3.3839(c), 3.3818(b)(2), 3.3830(g) and 3.3829(i) which the department anticipates will provide consumers ample information by which they can compare the premium rates and benefits of the two ADL and cognitive impairment policy or certificate with that of the two/three ADL and cognitive impairment policy or certificate. In response to comments, the department changed §3.3818(b)(2) to clarify that the information would always be provided to the individual to make the decision unless the policy is issued to a group policyholder who is an employer, labor union or continuing care retirement center. The amendments require the following safeguards: that a long-term care two/three ADL and cognitive impairment policy or certificate and application shall disclose the varying benefits in a common location and in equal prominence; that the marketing of a long-term care two/three ADL and cognitive impairment policy or certificate shall disclose all benefit levels within a common location and in equal prominence; and that if an insurer offers a two/three ADL and cognitive impairment policy or certificate to a prospective insured or group policy holder, the agent of the insurer must also offer the two ADL and cognitive impairment policy and obtain a written rejection or acknowledgement of such offer. Additionally, the amendments must be read in conjunction with existing rules, several of which are required to comply with federal law. Current §3.3838 requires all advertising to be filed with the department and must comply with Insurance Code Article 21.21 as well as 28 TAC Chapter 21, Subchapter B. Section 3.3839 addresses standards for marketing which includes a standard that any comparison of policies will be fair and accurate. Section 3.3832 dictates the content of the outline of coverage and that it be delivered to prospective applicants. Section 3.3840 requires a shoppers' guide be provided to all prospective applicants. The department will be revising its shoppers' guide to further educate consumers regarding these amendments. The department feels that the safeguards in the amendments and current rules will be very effective in preventing consumer confusion. In addition, the department recognizes there are other resources available to assist consumers in evaluating long term care and other coverage, including the Area Agencies on Aging through the Department on Aging and the Texas Agriculture Extension Service.

§3.3818: One commenter believes that the language regarding cognitive impairment is not clear and appears to possibly exclude §3.3818(a)(2) from §3.3818(b). The commenter proposed alternative language to clarify what it believes is the department's intent in this regard.

AGENCY RESPONSE: The amendment covers §3.3818(a)(2) in the requirements relating to §3.3818(b). The department believes that the commenter's concerns regarding the clarity of the cognitive impairment benefit trigger is addressed in §3.3818(b)(1)(D) in that the coverage is the same as that provided for two ADL, but has added clarifying language.

§3.3818: A commenter requested the department to clarify if it intends that a "company offering a policy under §3.3818(b) must include the same level of benefits for two ADL in that policy as the policy offered under §3.3818(a)."

AGENCY RESPONSE: The stand-alone two ADL and cognitive impairment policy or certificate does not have to provide the exact same benefit levels for the two ADL component of the two/three ADL and cognitive impairment policy or certificate. However, the two ADL component of the two/three ADL and cognitive impairment product cannot provide a lower benefit level than a benefit level that is appropriate for an individual as required by existing §3.3842. All benefit levels must be reasonable and adequate in relation to standard market conditions.

For: Continental Casualty Company, American Council of Life Insurance, Health Insurance Association of America, AEGON Insurance Group. Against:: Consumers Union and Office of Public Insurance Counsel.

The amendments are adopted under the Insurance Code Articles 3.70-12, 3.70-1, 3.51-6, 21.21, and §36.001 and §2001.021 of the Government Code. Article 3.70-12 provides that the commissioner shall establish specific standards for provisions of long-term care insurance policies and standards for full and fair disclosure and for the marketing of long-term care policies or certificates. It also authorizes the commissioner to issue any additional rules that are reasonably necessary and proper to carry out the minimum standards for long-term care insurance policies set forth in Article 3.70-12. Article 3.70-1 provides that the commissioner shall adopt rules and regulations establishing minimum standards for benefits for long-term care coverage under individual and group policies and certificates of accident and sickness insurance delivered or issued for delivery in this state including group coverages delivered or issued for delivery by companies subject to Chapter 20 of the Texas Insurance Code. Article 3.51-6 authorizes the commissioner to issue such rules and regulations as may be necessary to carry out provisions that relate to group coverage. Article 21.21 provides that the commissioner may promulgate rules to protect the public from unfair or deceptive acts or practices. Section 36.001 provides that the Commissioner of Insurance may adopt rules to execute the duties and functions of the Texas Department of Insurance only as authorized by statute. Section 2001.021 of the Government Code allows interested individuals or entities to petition a state agency to adopt requested rules.

§3.3818.Standards for Eligibility for Benefits.

(a)

A long-term care insurance policy or certificate shall contain provisions conditioning eligibility for benefits or services upon the occurrence of the following events:

(1)

the inability to perform, without assistance, any two activities of daily living, as set forth by the insurer; provided, however, that such activities of daily living shall include at a minimum those which are set forth and defined in §3.3804 of this title (relating to Definitions); or

(2)

the impairment of cognitive ability. For purposes of this subchapter, the term "impairment of cognitive ability" shall not be defined more restrictively than the deterioration or loss in intellectual capacity requiring substantial supervision for protection of self or others, as established by the clinical diagnosis of any licensed practitioner in this state authorized to make such a diagnosis. Such diagnosis shall include the patient's history and physical, neurological, psychological and/or psychiatric evaluations, and laboratory findings.

(b)

Any insurer or other entity that offers a long-term care insurance policy or certificate that complies with subsection (a) of this section may also offer a long-term care policy or certificate that provides coverage based on the inability to perform without assistance any three activities of daily living, provided:

(1)

the policy or certificate meets the requirements of subparagraphs (A) through (D) of this paragraph:

(A)

the policy and certificate shall provide coverage based on meeting the eligibility requirements of subsection (a)(1) of this section,

(B)

the coverage based on the inability to perform, without assistance, any three activities of daily living shall:

(i)

be identical to the coverage provided under subparagraph (A) of this paragraph;

(ii)

provide a level of benefits for facility coverage that is higher than the level of benefits payable for facility coverage under subparagraph (A) of this paragraph;

(iii)

provide a level of benefits for non-facility coverage that is not less than the level of benefits payable for non-facility coverage under subparagraph (A) of this paragraph; however, in complying with §3.3815(c) of this title (relating to Standards for Home Health and Adult Day Care Benefits), home health or adult day care services coverage must be a dollar amount equivalent to at least one-half of one year's coverage available for the nursing home benefit associated with the corresponding number of activities of daily living.

(C)

the activities of daily living shall include those set forth and defined in §3.3804 of this title for coverage provided under subparagraphs (A) and (B) of this paragraph;

(D)

coverage provided based on meeting the eligibility requirements of subsection (a)(2) of this section for impairment of cognitive ability shall be identical to the coverage provided under subparagraph (A) of this paragraph and the benefit level shall not be less than the applicable benefit level payable under subparagraph (B)(ii) or (B)(iii) of this paragraph; and

(2)

the insurer or other entity shall offer the prospective insured, or where the policy is offered to a group, the offer required by provisions of this paragraph shall be made to the group policyholder; except that in the instance where the group policy will not be issued to an employer, labor union, or continuing care retirement center, the offering shall be made to each prospective covered individual, the option to purchase a policy or certificate that provides benefits set out in subsection (a) of this section and obtain either: a written rejection of such offer or written acknowledgement of such offer. Written rejection or acknowledgment of offer may be by a rejection or acknowledgment receipt, attached to or made part of the application, or by a certificate of rejection or offer signed by the prospective insured or group policyholder if the group policyholder will be an employer, labor union, or continuing care retirement center.

(c)

For purposes of only subsection (b)(1)(B) of this section, the term "facility," to the extent coverage for care at any of the following is provided in the policy or certificate, means an assisted living facility, skilled nursing facility, extended care facility, intermediate care facility, convalescent nursing home, or maintenance or personal care facility.

§3.3829.Required Disclosure Provisions.

(a)

Long-term care insurance policies and certificates shall contain a renewability provision as required by §3.3822 of this title (relating to Minimum Standard for Renewability of Long-term Care Coverage). Such provision shall be appropriately captioned, shall appear on the first page of the policy, and shall clearly state the duration, where limited, of renewability and the duration of the coverage for which the policy is issued and for which it may be renewed.

(b)

Except for riders or endorsements by which the insurer effectuates a request made in writing by the policyholder under a long-term care insurance policy and/or certificate, all riders or endorsements added to a long-term care insurance policy and/or certificate after the date of issue or at reinstatement or renewal, which reduce or eliminate benefits or coverage in the policy and/or certificate, shall require a signed acceptance by the policyholder. After the date of policy issue, any rider or endorsement which increases benefits or coverage with a concomitant increase in premium during the policy term must be agreed to in writing signed by the policyholder, except if the increased benefits or coverage are required by law. Where a separate additional premium is charged for benefits in connection with riders or endorsements, such premium charge shall be set forth in the policy, certificate, rider, or endorsement.

(c)

A long-term care insurance policy and certificate which provides for the payment of benefits on standards described as usual and customary, reasonable and customary, or words of similar import, shall include a definition of such terms and an explanation of such terms in its accompanying outline of coverage.

(d)

If a long-term care insurance policy or certificate contains any limitations with respect to preexisting conditions, such limitations shall appear as a separate paragraph of the policy or certificate and shall be labeled as "Preexisting Condition Limitations."

(e)

Long-term care insurance applicants shall have the right to return the policy or certificate within 30 days of its delivery and to have the premium refunded if, after examination of the policy or certificate, the applicant is not satisfied for any reason. Long-term care insurance policies and certificates shall have a notice prominently printed on the first page or attached thereto stating in substance that the applicant shall have the right to return the policy or certificate within 30 days of its delivery and to have the premium refunded if, after examination of the policy or certificate, the applicant is not satisfied for any reason.

(f)

A long-term care insurance policy or certificate containing any limitations or conditions for eligibility other than those prohibited in the Insurance Code, Article 3.70-12, or §3.3824 of this title (relating to Preexisting Conditions Provisions) shall set forth a description of such limitations or conditions in a separate paragraph of the policy and certificate and shall label each paragraph "Limitations or Conditions on Eligibility for Benefits."

(g)

Long-term care insurance policies and certificates shall appropriately caption and describe the nonforfeiture benefit provision, if elected.

(h)

Long-term care insurance policies and certificates shall contain a claim denial provision which shall be appropriately captioned. Such provision shall clearly state that if a claim is denied, the insurer shall make available all information directly relating to such denial within 60 days of the date of a written request by the policyholder or certificate holder, unless such disclosure is prohibited under state or federal law.

(i)

A long-term care insurance policy and certificate which includes benefit provisions under §3.3818(b) of this title (relating to Standards for Eligibility for Benefits) shall disclose, within a common location and in equal prominence, a description of all benefit levels payable for the coverage described in §3.3818(b). Criteria utilized to determine eligibility for benefits shall be disclosed in all long-term care insurance policies and certificates, in the manner prescribed by §3.3818.

(j)

If the insurer intends for a long-term care insurance policy or certificate to be a qualified long-term care insurance contract as defined by the Internal Revenue Code of 1986, §7702B(b), the policy or certificate shall include disclosure language substantially similar to the following. "This policy is intended to be a qualified long-term care contract as defined by the Internal Revenue Code of 1986, §7702B(b)."

(k)

If the insurer does not intend for the policy to be a qualified long-term care insurance contract as defined by the Internal Revenue Code of 1986, §7702B(b), the policy or certificate shall include disclosure language substantially similar to the following. "This policy is not intended to be a qualified long-term care insurance contract. This long-term care insurance policy does not qualify the insured for the favorable tax treatment provided for in the Internal Revenue Code of 1986, §7702B."

§3.3830.Requirements for Application Forms and Replacement Coverage.

(a)

Individual, direct-response-solicited, and group long-term care insurance application forms shall include questions designed to elicit information as to whether, as of the date of application, the applicant has another long-term care insurance policy or certificate in force or the proposed insurance is intended to replace any other accident and sickness or long-term care insurance policy presently in force. A supplementary application or other form to be signed by the applicant and agent, except where the coverage is sold without an agent, containing such questions may be used. With regard to a replacement policy issued to an employer, labor union, or continuing care retirement community, the following questions may be modified only to the extent necessary to elicit information about health or long-term care insurance policies other than the group policy being replaced; provided, however, that the certificate holder has been notified of the replacement. The following questions shall be included in the application.

(1)

Do you have another long-term care insurance policy or certificate in force (including health care service contract, health maintenance organization contract)?

(2)

Did you have another long-term care insurance policy or certificate in force during the last 12 months?

(A)

If so, with which company?

(B)

If that policy lapsed, when did it lapse?

(3)

Are you covered by Medicaid?

(4)

Do you intend to replace any of your medical or health insurance coverage with this policy (certificate)?

(b)

Agents shall list any other health insurance policies and certificates they have sold to the applicant and shall also:

(1)

list policies and certificates sold which are still in force;

(2)

list policies and certificates sold in the past five years which are no longer in force.

(c)

Agents shall list any other health insurance policies or certificates the applicant has in force.

(d)

Upon a determination that a sale will involve replacement, an insurer or its agent, if that insurer is other than one using direct-response solicitation methods, shall furnish the applicant, prior to issuance or delivery of the individual long-term care insurance policy, a notice regarding replacement of accident and sickness or long-term care coverage. One copy of such notice shall be retained by the applicant and an additional copy signed by the applicant shall be retained by the insurer. The required notice shall be provided in the following manner.

Figure: 28 TAC §3.3830(d) (No change.)

(e)

Insurers using direct-response solicitation methods shall deliver a notice regarding replacement of accident and sickness or long-term care coverage to the applicant upon issuance of the policy or certificate. The required notice shall be provided in the following manner.

Figure: 28 TAC §3.3830(e) (No change.)

(f)

When replacement is intended, the replacing insurer shall notify, in writing, the existing insurer of the proposed replacement. The existing policy or certificate shall be identified by the insurer, name of the insured, and policy number or address including zip code. Such notice shall be made within five working days from the date the application is received by the replacing insurer at its home office, or the date the policy is issued, whichever is sooner.

(g)

An application for a long-term care policy or certificate that contains benefits under §3.3818(b) of this title (relating to Standards for Eligibility for Benefits) shall in equal prominence reflect the benefit levels payable for the inability to perform two activities of daily living, three activities of daily living, and cognitive impairment.

§3.3839.Standards for Marketing.

(a)

Every insurer, health care service plan, or other entity marketing long-term care insurance coverage in this state, directly or through its agents, shall establish marketing procedures to assure that:

(1)

any comparison of policies by its agents or other producers will be fair and accurate;

(2)

excessive insurance is not sold or issued;

(3)

every reasonable effort is made to identify whether a prospective applicant or enrollee for long-term care insurance already has accident and sickness or long-term care insurance and the types and amounts of any such insurance;

(4)

no person shall, in selling or offering to sell a long-term care policy, misrepresent a material fact;

(5)

the policy shall be delivered no later than 30 days after the application for the long-term care insurance policy or certificate is approved; and

(6)

auditable procedures are in place to verify compliance with this subsection.

(b)

Every insurer or other entity marketing long-term care insurance coverage in this state, directly or through its agents, shall ensure that the notice provided in paragraph (1) or (2) of this subsection, as appropriate, is prominently displayed by type, stamp, or other appropriate means on the first page of both the policy (or certificate) and the outline of coverage.

(1)

For any policy or certificate which contains inflation protection provisions, the notice shall read as follows: "Notice to buyer: This policy (or certificate) may not cover all of the costs associated with long-term care incurred by the policyholder (or certificate holder) during the period of coverage. The policyholder (or certificate holder) is advised to review carefully all policy limitations."

(2)

For any policy or certificate which does not contain inflation protection provisions, the notice shall read as follows: "Notice to buyer: This policy (or certificate) may not cover all of the costs associated with long-term care incurred by the policyholder (or certificate holder) during the period of coverage. The policyholder (or certificate holder) is advised to review carefully all policy limitations. In addition, the policyholder (or certificate holder) is advised that based on current health care cost trends, the benefits provided by this policy (or certificate) may be significantly diminished in terms of real value to the policyholder (or certificate holder), depending on the amount of time which elapses between the date of purchase and the date upon which the policyholder (or certificate holder) first becomes eligible for those benefits."

(c)

The marketing of a long-term care insurance policy or certificate which includes benefits provisions under §3.3818(b) of this title (relating to Standards for Eligibility for Benefits) shall disclose within a common location and in equal prominence a description of all benefit levels payable for coverage described in §3.3818(b).

(d)

In addition to the practices prohibited in the Insurance Code, Article 21.21, the following acts and practices in the marketing of long-term care policies or certificates in this state are prohibited.

(1)

Twisting-Knowingly making any misleading representation or incomplete or fraudulent comparisons of any insurance policies or insurers for the purpose of inducing, or tending to induce, any person to lapse, forfeit, surrender, terminate, retain, pledge, assign, borrow on, or convert any insurance policy or to take out a policy of insurance with another insurer.

(2)

High pressure tactics-Employing any method of marketing having the effect of or tending to induce the purchase of insurance through force, fright, threat, whether explicit or implied, or undue pressure to purchase or recommend the purchase of insurance.

(3)

Cold lead advertising-Making use directly or indirectly of any method of marketing which fails to disclose in a conspicuous manner that a purpose of the method of marketing is solicitation of insurance and that contact will be made by an insurance agent or insurance company.

(4)

Misrepresentation-Selling, marketing, offering, or advertising any insurance policy, certificate, or rider to such policy or certificate, which substantially meets the definition of long-term care insurance found in the Insurance Code Article 3.70-12, §2, but which provides benefits for a period of fewer than 12 months.

This agency hereby certifies that the adoption has been reviewed by legal counsel and found to be a valid exercise of the agency's legal authority.

Filed with the Office of the Secretary of State on February 9, 2000.

TRD-200001009

Lynda Nesenholtz

General Counsel and Chief Clerk

Texas Department of Insurance

Effective date: February 29, 2000

Proposal publication date: December 3, 1999

For further information, please call: (512) 463-6327