Florida Office of Insurance Regulation Issues Informational Memorandum on Insurer Continuity of Operation Plans on COVID-19

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On March 16, 2020, the Florida Office of Insurance Regulation ("OIR") issued an Informational Memorandum OIR-20-03M.  In that Memorandum, the Commissioner urged all regulated insurers to heed the guidance memos from the Centers for Disease Control and Prevention ("CDC"), as well as the Florida Department of Health ("DOH"), for businesses and employers. All companies regulated by the state OIR are required to review and update all Business Continuity Plans and/or Continuity of Operations “immediately”.  Such operations as policy issuance, premium collection, claims adjustment and payment, and policyholder services, must account for DOH and CDC guidance surrounding COVID-19. The OIR required immediate notice to the department by any regulated insurer, if that insurer has had to activate its Business Continuity or Continuity of Operations plans. Insurers must advise the DOI the date the plan was activated, and the name, phone number and email address of the company’s point of contact for continuity plan activation. Further, if in response to COVID-19 any business operations are compromised to the extent it may jeopardize ability to provide essential services to policyholders the company must immediately notify the DOI, by providing detailed information regarding the extent to which business operations are compromised, including how it impacts policyholders, and provide the name, phone number and email address of the point of contact for that issue.

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