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Arizona Department of Insurance Regulatory Bulletin 2020-04

On April 16, 2020, the Arizona Department of Insurance issued Regulatory Bulletin 2020-04, addressing the flexibility that the Agency asks the Insurance Industry to practice.

This Bulletin addresses the financial challenges faced by insureds due to the COVID-19 pandemic. Accordingly, the Bulletin encourages insurers to work with their customers to take steps “so that coverage continues, policies do not lapse, and claimants have adequate time to fulfill requirements to obtain coverage/claim payment”. To achieve these objectives, the Bulletin highlights a number of considerations for insurers which provide flexibility to their customers including:

  • Extended deadlines and grace periods and reduction or forgiveness of late fees, interest and penalties for late premium payments
  • Suspending the use of credit reports
  • Delays in premium increases
  • Extended timeframes to renew licenses, submit claims or undergo medical examinations

In addition to providing steps that insurers are urged to take, the Bulletin also encourages insurance consumers to contact insurers to ask about other forms of relief that may be available, noting that some insurers have voluntarily agreed to:

  • Extend premium timeframes
  • Provide premium relief or waive or reduce cost-sharing
  • Waive exclusions
  • Relax claims handling requirements.

Insurers will need to file policy changes to make the changes outlined by the Department. The Bulletin states that insurers which implement changes during the COVID-19 public health emergency will not be considered in violation of the Unfair Trade Practices Act. Nor will they be considered prohibited inducement statutes. However the Bulletin states that insurers which establish customer relief programs must act “in a uniform, consistent manner that does not result in an unfair discrimination between eligible insurers.”

For more information, contact Greg Harris at or visit

Tags: COVID-19 Rapid Response Team, Insurance Services
  • Gregory Y. Harris

    Greg Harris practices administrative law, healthcare law, procurement law, and government relations. He frequently writes and presents on these and related issues to legal, government, and trade groups in Arizona.

    Administrative Law

    Greg helps clients with a wide variety of state and ...

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