SERFF Tracking #: KOCO-132872298 State Tracking #: KOCO-132872298 Company Tracking #:

State: Virginia Filing Company: Knights of Columbus TOI/Sub-TOI: LTC Annual Rate Report/LTCINLM Product Name: LTC Annual Rate Report (LTCINLM) - CY2020 Project Name/Number: LTC Annual Rate Report (LTCINLM) - CY2020/

Filing at a Glance Company: Knights of Columbus Product Name: LTC Annual Rate Report (LTCINLM) - CY2020 State: Virginia TOI: LTC Annual Rate Report Sub-TOI: LTCINLM Filing Type: LTC Annual Rate Report Date Submitted: 06/12/2021 SERFF Tr Num: KOCO-132872298 SERFF Status: Closed-Filed State Tr Num: KOCO-132872298 State Status: Filed Co Tr Num:

Effective 06/30/2021 Date Requested: Author(s): Barbara Caruso Reviewer(s): Bill Dismore (primary) Disposition Date: 06/23/2021 Disposition Status: Filed Effective Date:

PDF Pipeline for SERFF Tracking Number KOCO-132872298 Generated 06/25/2021 12:23 AM SERFF Tracking #: KOCO-132872298 State Tracking #: KOCO-132872298 Company Tracking #:

State: Virginia Filing Company: Knights of Columbus TOI/Sub-TOI: LTC Annual Rate Report/LTCINLM Product Name: LTC Annual Rate Report (LTCINLM) - CY2020 Project Name/Number: LTC Annual Rate Report (LTCINLM) - CY2020/

General Information Project Name: LTC Annual Rate Report (LTCINLM) - CY2020 Status of Filing in Domicile: Not Filed Project Number: Date Approved in Domicile: Requested Filing Mode: Informational Domicile Status Comments: , our state of domicile, does not require. Explanation for Combination/Other: Market Type: Individual Submission Type: New Submission Individual Market Type: Overall Rate Impact: Filing Status Changed: 06/23/2021 State Status Changed: 06/23/2021 Deemer Date: Created By: Barbara Caruso Submitted By: Barbara Caruso Corresponding Filing Tracking Number:

State TOI: LTC Annual Rate Report 2021 Filing Description: The Knights of Columbus (NAIC #58033) is submitting its LTC Annual Rate Report for calendar year 2020 for policies issued on or after October 1, 2003 that are no longer marketed (LTCINLM). This includes the following forms:

LTC01-VA 1-03 Comprehensive LTC Contract approved on 7/23/2003 Submission # 007 0000020704 NHC01-VA 1-03 Facility Only Contract approved on 7/23/2003 Submission # 007 0000020704

This report is being submitted in connection with 14VAC5-200-125 for informational (reporting) purposes only.

There is no rate increase history for these products as the Knights of Columbus has never requested a rate increase since initial approval of the products in 2003. Please note these products are guaranteed renewable which means the contract may be kept in force during the lifetime of the insured by paying premiums when due, subject to the Maximum Lifetime Benefit.

The number of policies in force as of 12/31/2020: a) LTC01-VA 1-03: 951 b) NHC01-VA 1-03: 213

Company and Contact Filing Contact Information Barbara Caruso, Senior Compliance [email protected] Analyst 1 Columbus Plaza 203-752-4364 [Phone] New Haven, CT 06510-3326 203-752-4119 [FAX]

Filing Company Information Knights of Columbus CoCode: 58033 State of Domicile: Connecticut 1 Columbus Plaza Group Code: Company Type: Fraternal New Haven, CT 06510-3326 Group Name: State ID Number: (203) 752-4000 ext. 4326[Phone] FEIN Number: 06-0416470

PDF Pipeline for SERFF Tracking Number KOCO-132872298 Generated 06/25/2021 12:23 AM SERFF Tracking #: KOCO-132872298 State Tracking #: KOCO-132872298 Company Tracking #:

State: Virginia Filing Company: Knights of Columbus TOI/Sub-TOI: LTC Annual Rate Report/LTCINLM Product Name: LTC Annual Rate Report (LTCINLM) - CY2020 Project Name/Number: LTC Annual Rate Report (LTCINLM) - CY2020/

Filing Fees State Fees

Fee Required? No Retaliatory? No Fee Explanation:

PDF Pipeline for SERFF Tracking Number KOCO-132872298 Generated 06/25/2021 12:23 AM SERFF Tracking #: KOCO-132872298 State Tracking #: KOCO-132872298 Company Tracking #:

State: Virginia Filing Company: Knights of Columbus TOI/Sub-TOI: LTC Annual Rate Report/LTCINLM Product Name: LTC Annual Rate Report (LTCINLM) - CY2020 Project Name/Number: LTC Annual Rate Report (LTCINLM) - CY2020/

Correspondence Summary Dispositions Status Created By Created On Date Submitted Filed Bill Dismore 06/23/2021 06/23/2021

PDF Pipeline for SERFF Tracking Number KOCO-132872298 Generated 06/25/2021 12:23 AM SERFF Tracking #: KOCO-132872298 State Tracking #: KOCO-132872298 Company Tracking #:

State: Virginia Filing Company: Knights of Columbus TOI/Sub-TOI: LTC Annual Rate Report/LTCINLM Product Name: LTC Annual Rate Report (LTCINLM) - CY2020 Project Name/Number: LTC Annual Rate Report (LTCINLM) - CY2020/

Disposition

Disposition Date: 06/23/2021 Effective Date: Status: Filed Comment:

Overall % Overall % Written Premium Number of Policy Written Maximum % Minimum % Company Indicated Rate Change for Holders Affected Premium for Change Change Name: Change: Impact: this Program: for this Program: this Program: (where req'd): (where req'd): Knights of Columbus 0.000% 0.000% $0 1,164 $2,296,941 0.000% 0.000%

Schedule Schedule Item Schedule Item Status Public Access Supporting Document Actuarial Memorandum Received & Acknowledged Yes Supporting Document Product Checklist Received & Acknowledged Yes Supporting Document LTC Annual Report Instructions Received & Acknowledged Yes Rate LTCINLM Filed Yes

PDF Pipeline for SERFF Tracking Number KOCO-132872298 Generated 06/25/2021 12:23 AM SERFF Tracking #: KOCO-132872298 State Tracking #: KOCO-132872298 Company Tracking #:

State: Virginia Filing Company: Knights of Columbus TOI/Sub-TOI: LTC Annual Rate Report/LTCINLM Product Name: LTC Annual Rate Report (LTCINLM) - CY2020 Project Name/Number: LTC Annual Rate Report (LTCINLM) - CY2020/

Rate Information Rate data applies to filing.

Filing Method: SERFF Rate Change Type: Neutral Overall Percentage of Last Rate Revision: 0.000% Effective Date of Last Rate Revision: 06/30/2020 Filing Method of Last Filing: SERFF SERFF Tracking Number of Last Filing: KOCO-132437768

Company Rate Information Overall % Overall % Written Premium Number of Policy Written Maximum % Minimum % Company Indicated Rate Change for Holders Affected Premium for Change Change Name: Change: Impact: this Program: for this Program: this Program: (where req'd): (where req'd): Knights of Columbus 0.000% 0.000% $0 1,164 $2,296,941 0.000% 0.000%

PDF Pipeline for SERFF Tracking Number KOCO-132872298 Generated 06/25/2021 12:23 AM SERFF Tracking #: KOCO-132872298 State Tracking #: KOCO-132872298 Company Tracking #:

State: Virginia Filing Company: Knights of Columbus TOI/Sub-TOI: LTC Annual Rate Report/LTCINLM Product Name: LTC Annual Rate Report (LTCINLM) - CY2020 Project Name/Number: LTC Annual Rate Report (LTCINLM) - CY2020/

Rate/Rule Schedule

Item Schedule Affected Form Numbers No. Item Document Name (Separated with commas) Rate Action Rate Action Information Attachments Status 1 LTCINLM LTC01-VA 1-03, NHC01-VA 1- Other Previous State Filing Number: LTCI_VA_NLM- 03 KOCO-132437768 2020_Certification.pdf, Rate Action Other Explanation: Annual Certification

PDF Pipeline for SERFF Tracking Number KOCO-132872298 Generated 06/25/2021 12:23 AM

Annual Rate Report for Long-Term Care Policies Issued On or After October 1, 2003 that are No Longer Marketed Reporting Period January 1st, 2020 to December 31, 2020

Company Name Knights of Columbus

Company NAIC Number 58033

Form Number(s) LTC01-VA 1-03 NHC01-VA 1-03

Issue Dates October 1, 2003 to July 23, 2014

Previous SERFF Filing Number KOCO-132437768

Current SERFF Filing Number KOCO-132865865

I, Jason Ard, am a member of the American Academy of Actuaries. I meet the Academy’s qualification standards for rendering this opinion and am familiar with the requirements for filing and reviewing long-term care insurance premiums.

In my opinion, the premium rate schedules are sufficient to cover anticipated costs under best estimate assumptions and the premium rate schedules are reasonably expected to be sustainable over the life of the policies with no future premium increases anticipated. Based on my review of recent experience of the policies involved, in my opinion, no rate action is necessary as a result of this analysis. However, if interest rates continue to stay low or our claims experience deteriorates further, corrective action may be necessary in the future.

In forming my opinion, I have used actuarial assumptions and actuarial methods and such tests of the actuarial calculations as I considered necessary. Attached is an actuarial memorandum that provides the historical experience and the expected future and lifetime loss ratios based on the current best-estimate assumptions; and a detailed description and actuarial support for each assumption used in the projections.

Jason Ard, ASA, MAAA Senior Actuarial Associate Knights of Columbus One Columbus Plaza New Haven, CT 06510-3326 (203) 752-4339 [email protected] May 28, 2021

LTCINLM Page 1 of 10

SERFF Tracking #: KOCO-132872298 State Tracking #: KOCO-132872298 Company Tracking #:

State: Virginia Filing Company: Knights of Columbus TOI/Sub-TOI: LTC Annual Rate Report/LTCINLM Product Name: LTC Annual Rate Report (LTCINLM) - CY2020 Project Name/Number: LTC Annual Rate Report (LTCINLM) - CY2020/

Supporting Document Schedules Satisfied - Item: Actuarial Memorandum Comments: Attachment(s): LTCI_VA_NLM-2020_Memorandum.pdf Item Status: Received & Acknowledged Status Date: 06/23/2021

Satisfied - Item: Product Checklist Comments: Attachment(s): VA_NLM_Checklist.pdf Item Status: Received & Acknowledged Status Date: 06/23/2021

Satisfied - Item: LTC Annual Report Instructions Comments: I have read the instructions and believe the proper forms are uploaded under the appropriate tabs. Attachment(s): Item Status: Received & Acknowledged Status Date: 06/23/2021

PDF Pipeline for SERFF Tracking Number KOCO-132872298 Generated 06/25/2021 12:23 AM

KNIGHTS OF COLUMBUS (The Order) New Haven, Connecticut 06510-3326

ACTUARIAL MEMORANDUM ANNUAL SUBMISSION

Individual, Guaranteed Renewable, Long-Term Care Insurance Policies Issued On or After October 1, 2013 that are No Longer Marketed

Virginia Filing

May 28, 2021

PURPOSE

The purpose of this memo is to disclose the expected future and lifetime loss ratios based on current best-estimate assumptions.

PRODUCT FORM NUMBER

Forms: Tax-Qualified Comprehensive Long-Term Care Insurance Contract LTC01-VA 1-03

Tax-Qualified Facility-Only Long-Term Care Insurance Contract NHC01-VA 1-03

LTCINLM Page 2 of 10

Description of experience assumptions and their relationship to the initial pricing assumptions Initial Pricing Assumptions

1. Morbidity: Institutional Benefits: The 1985 and 1995 National Nursing Home Surveys provide the source data upon which the Institutional Benefit rates are developed. The source data has been adjusted to reflect: (1) surveys of nursing home resident cohorts indicate certain long-term residents would not meet the benefit eligibility criteria under the contract, and (2) the Medicaid population, which exhibits worse health status and greater long-term care service use, is included in this survey.

Home and Community Benefits: (only for LTC01-VA 1-03) The 1989 and 1994 National Long-Term Care Survey of disabled elders in the Community is the source data upon which the Home and Community Benefit rates are developed. The source data includes cognitive impairment as a cause of disability. Loss is based on self-reporting of:  Dependency in 2 or more of 6 ADL’s, or  Cognitive impairment (e.g. as measured by performance on the SPMSQ)

Adjustments to the source data were made to reflect the selection effect of underwriting and the non-duplication of benefits with other payment sources.

2. Gender: 50% Female, 50% Male

3. Mortality: The underlying mortality basis is that provided by the Knights of Columbus which is an adjusted 1975-80 Basic Ultimate Mortality table.

4. Expenses: Acquisition: Under age 72: $148 per policy Age 72 and over: $315 per policy General Office Expense: 4% of gross premium Claims Expense: 2% of paid claims Premium Tax: Not Applicable to Fraternal Benefit Societies Sales and marketing: Year 1: 75% of gross premium Year 2-3: 12% of gross premium Year 4-5: 6% of gross premium

5. Interest Assumption: 6.25%

LTCINLM Page 3 of 10

6. Surplus Contribution: Up to age 60: 3% of gross premium Age 60 to 69: 7% of gross premium Age 70 and over: 12% of gross premium

7. Voluntary Terminations:

Year 1: 8% Year 2: 6% Year 3: 4% Year 4: 3% Year 5+: 2%

8. Underwriting Effect : % Reduction in the Expected Claims

Year 1: 70% Year 2: 60% Year 3: 50% Year 4: 40% Year 5: 30% Year 6: 20% Year 7: 10% Year 8+: 0%

(Source: Extracts from original Actuarial Memorandum, signed by Donald M. Charsky, FSA, MAAA, Consultant (LifePlans) )

Experience since initial pricing

Interest

The estimated net earnings on the United States Long-Term Care portfolio of assets was approximately 3.90% as of March 31, 2021 which is 2.35% lower that the investment return assumed in the original pricing. Credibility does not apply to this assumption as there are no claims or decrements to measure. As mentioned above, the continued downward trend on interest rates is a concern and something we are monitoring.

Lapse

Our lapse rates are approximately 43% of those rates assumed in initial pricing. In reviewing this assumption, I relied on a Knights of Columbus LTC lapse study which I reviewed for reasonableness. This study is a policy year study of our entire LTC block of business from January 1, 2000 to February 28,2021. We anticipate similar lapse experience for all our LTC policies.

LTCINLM Page 4 of 10

The lapse study had a total of 9,006 lapses, or 100% credibility based on Limited Fluctuation Credibility Theory with parameters of p=90% and r=3% where 3,007 is the number of lapses for full credibility. The Actual to Expected (A/E) Ratios of this study are analyzed in the table below by policy year. Overall the A/E is 43% by Count.

LTC Lapse Study Lapse By Count Policy Rate Actual Lapse A/E Year Assumption Lapses Rate Ratio 1 8% 2,822 4.2% 52% 2 6% 1,531 2.5% 41% 3 4% 1,010 1.7% 43% 4 3% 797 1.4% 48% 5 2% 573 1.1% 55% 6+ 2% 2,273 0.7% 33% All Years N/A 9,006 1.4% 43%

Mortality

We experience select mortality instead of the ultimate basis as assumed in our original pricing. Our mortality rates are approximately 37% of those rates assumed in initial pricing. In reviewing this assumption, I relied on a Knights of Columbus LTC mortality study which I reviewed for reasonableness. This study is a policy year study of our entire LTC block of business from January 1, 2000 to March 31, 2020. We anticipate similar mortality experience for our LTC policies.

The mortality study had a total of 3,484 deaths, or 100% credibility based on Limited Fluctuation Credibility Theory with parameters of p=90% and r=3% where 3,007 is the number of deaths for full credibility. The Actual to Expected (A/E) Ratios of this study are analyzed in the table below by policy year. Overall the A/E is 37% by Count.

LTC Mortality Study By Count Policy Mortality A/E Year Deaths Rate Ratio 1 85 0.13% 16% 2 117 0.20% 22% 3 135 0.24% 24% 4 160 0.30% 27% 5 174 0.35% 29% 6 163 0.37% 27% 7 177 0.45% 30% 8 196 0.54% 33% 9 220 0.67% 37% 10 232 0.79% 39% 11 + 1,825 1.54% 52% Total 3,484 0.60% 37%

LTCINLM Page 5 of 10

Morbidity

Offsetting adverse experience reported above is the fact that our current morbidity experience is about 27% of what was assumed in the original pricing (Source: 2020 Company LTC Claim Incidence Study using data as of 3/31/2020). This experience is based on 1,738 claims or 76% credibility based on Limited Fluctuation Credibility Theory with parameters of p=90% and r=3% where 3,007 is the number of claims for full credibility. This business has an average duration of 11 years.

Post-Rate Stabilization LTC01 1-03 Earned Claim Loss Year Premiums Incurred ratios 2011 20,645,327 1,011,009 5% 2012 23,667,807 1,743,438 7% 2013 27,085,882 2,677,653 10% 2014 32,173,810 3,561,432 11% 2015 34,764,779 4,435,959 13% 2016 35,442,122 6,430,544 18% 2017 35,620,240 7,873,383 22% 2018 35,930,008 6,353,659 18% 2019 36,344,681 9,315,594 26% 2020 36,767,349 10,415,094 28%

Post-Rate Stabilization NHC01 1-03 Earned Claim Loss Year Premiums Incurred ratios 2011 5,567,560 194,566 3% 2012 6,529,973 395,912 6% 2013 7,590,572 1,207,254 16% 2014 9,154,994 1,237,057 14% 2015 9,862,900 1,694,910 17% 2016 9,949,651 1,152,244 12% 2017 9,998,476 2,032,760 20% 2018 10,095,093 3,490,494 35% 2019 10,208,343 2,944,433 29% 2020 10,291,104 689,705 7%

LTCINLM Page 6 of 10

Best assumptions used in determining Loss Ratios

Projected Lifetime loss ratio

Same as initial pricing with the following exceptions which apply to both forms:

(1) Discount rate based on an interest rate of 3.75%. This provides a margin compared to our estimated net earnings of 3.90%. This is an update to this assumption from the prior year so we show projected loss ratios below at both 4.00% and 3.75% for comparison.

(2) Lapse rates: we have multiplied our lapse rates by a factor of 0.35, or a reduction of 65%. The 35% assumed provides a margin when compared to the Actual to Expected experience of 43%.

(3) Mortality rates: we have adjusted our mortality rates by the following factors. This assumption currently does not have a margin.

Year 1: 0.20 Year 2: 0.30 Year 3: 0.40 Year 4: 0.50 Year 5: 0.60 Year 6: 0.70 Year 7: 0.80 Year 8: 0.90 Year 9+: 1.00

(4) Claim Costs: we have adjusted them by a factor of 0.85. The 85% provides a margin compared to the Actual to Expected Incurred Claims of 27% we experienced.

Historical loss ratios combined with Projected future loss ratios

Same assumptions as used for Projected Lifetime Loss Ratio, except that our historical experience is used for the first eleven (11) durations.

We have converted our calendar experience, as reported in section “Experience since initial pricing” to durational loss ratios. For example, calendar year 2020 experience loss ratio is assumed to represent historical loss ratio for duration 11.

LTCINLM Page 7 of 10

For Long-Term Care Policy Form LTC01-VA 1-03

Projected Lifetime Loss Ratio

Year Loss Ratios Year Base Policy Year Base Policy Year Base Policy 1 8% 11 80% 21 192% 31 334% 2 11% 12 89% 22 205% 32 355% 3 15% 13 98% 23 232% 33 397% 4 21% 14 113% 24 249% 34 433% 5 28% 15 129% 25 264% 35 490% 6 35% 16 138% 26 306% 36 590% 7 44% 17 155% 27 329% 37 664% 8 54% 18 171% 28 353% 38 651% 9 64% 19 182% 29 367% 39 757% 10 73% 20 176% 30 362% 40 886%

Lifetime 67.8% 69.0% Discounted rate 4.00% 3.75%

Historical Loss Ratios combined with Projected Future Loss Ratios Year Loss Ratios Year Base Policy Year Base Policy Year Base Policy 1 5% 11 28% 21 192% 31 334% 2 5% 12 89% 22 205% 32 355% 3 5% 13 98% 23 232% 33 397% 4 5% 14 113% 24 249% 34 433% 5 10% 15 129% 25 264% 35 490% 6 13% 16 138% 26 306% 36 590% 7 18% 17 155% 27 329% 37 664% 8 22% 18 171% 28 353% 38 651% 9 18% 19 182% 29 367% 39 757% 10 26% 20 176% 30 362% 40 886%

Lifetime 52.1% 53.4% Discounted rate 4.00% 3.75%

LTCINLM Page 8 of 10

For Long-Term Care Policy Form NHC01-VA 1-03

Projected Lifetime Loss Ratio

Year Loss Ratios Year Base Policy Year Base Policy Year Base Policy 1 5% 11 77% 21 196% 31 356% 2 8% 12 87% 22 208% 32 391% 3 11% 13 98% 23 237% 33 444% 4 17% 14 114% 24 254% 34 490% 5 23% 15 130% 25 273% 35 595% 6 29% 16 139% 26 319% 36 717% 7 38% 17 157% 27 344% 37 808% 8 47% 18 175% 28 369% 38 793% 9 58% 19 185% 29 385% 39 922% 10 69% 20 179% 30 381% 40 1081%

Lifetime 66.1% 67.5% Discounted rate 4.00% 3.75%

Historical Loss Ratios combined with Projected Future Loss Ratios

Year Loss Ratios Year Base Policy Year Base Policy Year Base Policy 1 3% 11 7% 21 196% 31 356% 2 3% 12 87% 22 208% 32 391% 3 3% 13 98% 23 237% 33 444% 4 3% 14 114% 24 254% 34 490% 5 16% 15 130% 25 273% 35 595% 6 17% 16 139% 26 319% 36 717% 7 12% 17 157% 27 344% 37 808% 8 20% 18 175% 28 369% 38 793% 9 35% 19 185% 29 385% 39 922% 10 29% 20 179% 30 381% 40 1081%

Lifetime 53.5% 54.8% Discounted rate 4.00% 3.75%

LTCINLM Page 9 of 10

Jason Ard, ASA, MAAA Senior Actuarial Associate Knights of Columbus One Columbus Plaza New Haven, CT 06510-3326 (203) 752-4339 [email protected]

May 28, 2021

LTCINLM Page 10 of 10

Review Requirements Checklist INDIVIDUAL LONG-TERM CARE INSURANCE (LTCI) (FORMS)

NOTICE: This checklist must be completed in its entirety and included with each submitted form. Failure to provide a completed checklist will result in a delay of the review of the submission and may result in rejection of the filing.

This document is intended to assist carriers in preparing form filings for approval by the Bureau of Insurance. It provides guidance based on current Virginia laws and regulations. It should be noted, however, that this checklist should not be used exclusive of other important resources, including, but not limited to, any and all other applicable state insurance laws and associated rules and regulations. It is the responsibility of the carriers to verify that submitted forms comply with all relevant statutory and regulatory requirements. Note that some regulatory references in the comments column are paraphrased. Please review the applicable citation for the full text of the requirement.

You can find out more about related laws, rules and orders from the Administration of Insurance Regulation section of our site.

The Forms and Rates Section of the Life and Health Division will review submissions based on the requirements noted in this checklist. Please contact this Section at (804) 371-9532 if you have questions or need additional information about these requirements.

Company Name: Knights of Columbus Third Party Filer: n/a SERFF Tracking Number: KOCO-132865865 Form Number(s): LTC01-VA 1-03, NHC01-VA 1-03

Individual Long-Term Care Insurance (LTCI) (FORMS) Virginia 1st Edition July 2001 Page 1 of 9 Updated: April 2020 Review Requirements Checklist INDIVIDUAL LONG-TERM CARE INSURANCE (LTCI) (FORMS)

REVIEW REQUIREMENTS REFERENCES COMMENTS PG #

1BGeneral Filing Requirements Source of Filing 14 VAC 5-101-40 Filings shall be submitted in SERFF or submitted in writing to the Commission. If filed by a third-party, filing authorization must be included. n/a Filing Description 14 VAC 5-101-50 C 1 Filing description must include the type of insurance form, including a description n/a of the form and the market for which the form is intended; intentions to concentrate on a specialized market should be noted. 14 VAC 5-101-50 C 2 Filing description must include the form number of each form that is being filed. n/a 14 VAC 5-101-50 C 3 Filing description must state whether submitted form is new, or if replacing, n/a revising, or modifying a previously approved form, and the exact changes that are intended. 14 VAC 5-101-50 C 4 Filing description must identify any change in benefits and indicate whether the change affects premium rates for the form. n/a 14 VAC 5-101-50 C 5 Filing description must state if approval of a form submitted has been withdrawn by another regulatory body and the reasons for such a withdrawal. n/a

14 VAC 5-101-50 F Any form filed that is to be used with a previously approved form, including an n/a application, shall identify the form number, approval date, and SERFF or state tracking number in the new filing. 14 VAC 5-101-50 G Any amendment, endorsement, or rider that intends to revise a previously n/a approved form shall be accompanied by the previously approved form filed as supporting documentation.

2B HELP TIP: If a form filing is submitted as new in Virginia, but was previously disapproved, n/a withdrawn, or rejected in Virginia, please provide details such as the SERFF or State tracking information, form number, and the date that the form filing was disapproved, withdrawn, or rejected if available.

3BForms

4B Form Number 14 VAC 5-101-60 1 Form Number must appear in the lower left-hand corner of the first page of the n/a form. It shall consist of numbers, letters, or a combination of both. The form number shall distinguish the form from all other forms used by the company. 5BCompany Name and Address 14 VAC 5-101-60 2 The full licensed name of the company, including the address of the home office, n/a shall appear in prominent print at the top of the cover page of any policy, application, or enrollment form. The full licensed name of the company shall appear in prominent print on all other forms.

6BMarketing Name or Logo 14 VAC 5-101-60 3 A marketing name or logo also may be used on the form, provided that the marketing name or logo does not mislead as to the identity of the filing company. n/a Individual Long-Term Care Insurance (LTCI) (FORMS) Virginia 1st Edition July 2001 Page 2 of 9 Updated: April 2020 Review Requirements Checklist INDIVIDUAL LONG-TERM CARE INSURANCE (LTCI) (FORMS)

REVIEW REQUIREMENTS REFERENCES COMMENTS PG #

14 VAC 5-101-60 4 The cover page of a policy also shall include the address of an office that will n/a administer the policy, if different from the home office, a company telephone number, and company website address.

7BFinal Form – John Doe 14 VAC 5-101-60 5 Form must be submitted in “final form” and in “John Doe fashion” to indicate its intended use. n/a

8BElectronic Version 14 VAC 5-101-60 6 Each form that is to be used in an electronic version shall be filed in a format that matches the electronic version exactly. n/a 9BReadability 14 VAC 5-101-70 A Each form submitted for review or approval shall be written in simplified language, n/a logically and clearly arranged, printed in a legible format and understandable to a person of average intelligence without special insurance knowledge or training. 14 VAC 5-101-70 B A policy of more than three pages shall include a table of contents listing the principal sections and provisions and the pages on which they are found. n/a 14 VAC 5-101-70 C Defined words and terms shall be placed in a separate definition section that is clearly identified, unless only used in one section. n/a

14 VAC 5-101-70 D A policy shall be divided into logically arranged sections with an appropriately n/a named caption or heading for ease in locating desired content. Captions and headings shall be clearly set apart from the general text.

10BType size 14 VAC 5-101-70 E Any form submitted for review or approval shall be printed in at least 10-point type size. n/a

14 VAC 5-101-70 F Any policy shall achieve a minimum Flesch reading ease score of 50 or an n/a equivalent score using another comparable test, unless otherwise specified by statute, or an exception requested pursuant to 14 VAC 5-101-70 G. Variability 14 VAC 5-101-80 Use of variable bracketed information shall be limited. Use of brackets within n/a brackets is not permitted. Each instance of variable text shall appear in brackets on a form and shall be separately and completely explained in detail in a Statement of Variability document. Each explanation of variability shall appear in the same order that it appears on the form. Additional guidance is attached to SERFF General Instructions.

Certificate of Compliance 14 VAC 5-101-110 Each form filing shall contain a Certificate of Compliance signed by an officer of the n/a company certifying the Flesch reading ease score of at least 50; that a review of the form has been conducted and is consistent and complies with the requirements of Title 38.2 and applicable rules and regulations; and a statement that failure to comply with these requirements will result in disapproval of the filing.

Individual Long-Term Care Insurance (LTCI) (FORMS) Virginia 1st Edition July 2001 Page 3 of 9 Updated: April 2020 Review Requirements Checklist INDIVIDUAL LONG-TERM CARE INSURANCE (LTCI) (FORMS)

REVIEW REQUIREMENTS REFERENCES COMMENTS PG #

Contents of Policies § 38.2-305 A Each policy/contract shall specify the: n/a (1) The names of parties to the contract, (2) The subject of the insurance, (3) The risk insured against, (4) The time the insurance takes effect, and the period during which the insurance is to continue, (5) A statement of premium, (6) Conditions pertaining to the insurance. Important Notice § 38.2-305 B Each new or renewal policy/contract/certificate/evidence of coverage shall be accompanied by an important notice as stated in the statute. n/a Arbitration § 38.2-312 Contract may not deprive courts of Virginia jurisdiction in actions against insurer. Arbitration may not be binding. n/a Fraud Notice § 38.2-316 D 1 Title 38.2 of the Code of Virginia does not define “Insurance Fraud”. Any fraud n/a notice that includes the term “insurance fraud” is not in compliance with this section of the Code. In Virginia, a fraud notice relating to , annuities, accident and sickness, health maintenance organizations, health services plans, credit accident and sickness and credit life insurance should not include references to imprisonment or fines. Variations in a notice warning of consequences of making fraudulent statements will be considered. Handicapped Child Coverage § 38.2-3409 Upon termination due to age, coverage will be continued for: n/a (1) Persons incapable of self-sustaining employment by reason of intellectual disability or physical handicap; and (2) Chiefly dependent on the insured for support and maintenance.

Additional premium may be charged based upon class of risks. Entire Consideration § 38.2-3500 A 1 The entire consideration is expressed in the policy. n/a Effective-Termination Time § 38.2-3500 A 2 The time (clock time) the policy becomes effective and terminates is expressed in the policy. n/a DMAS Payor of Last Resort § 38.2-3500 A 7 Every accident and health policy must contain a statement indicating the Department of Medical Assistance Services as the payor of last resort. n/a Definition of Eligible Family § 38.2-3500 C The definition establishes that eligible dependent children may not be required to members live in the household as the policyowner. n/a 30-Day Free Look § 38.2-5208 n/a

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0BGeneral Provisions Entire Contract § 38.2-3503 A 1 The provision defines the contents of the entire contract. n/a Grace Period § 38.2-3503 A 3 The provision defines the grace period and length of the various acceptable grace periods. n/a Reinstatement § 38.2-3503 A 4 The regulation provides for an extended reinstatement period in the event of 14 VAC 5-200-65 B policy lapse due to cognitive impairment. n/a Notice of Claim § 38.2-3503 A 5 n/a Claim Forms § 38.2-3503 A 6 n/a Proof of Loss § 38.2-3503 A 7 n/a Time of Payment of Claims § 38.2-3503 A 8 The provision specifies when benefits will be paid. n/a Payment of Claims § 38.2-3503 A 9 The provision specifies to whom benefits will be paid. n/a Physical Examinations and § 38.2-3503 A 10 Autopsy n/a Legal Actions § 38.2-3503 A 11 n/a Change of Beneficiary § 38.2-3503 A 12 (For payment to beneficiaries, see Payment of Claims provision-§ 38.2-3503 9). n/a Age Limit § 38.2-3513 A If the policy establishes an age-limit after which coverage will no longer be n/a effective, and if the date falls within a period for which a premium is accepted by the insurer or the insurer accepts a premium after the date, the coverage provided by the policy will continue in force until the end of the period for which the premium has been accepted. Age Misstated § 38.2-3513 B If the age of the insured has been misstated and the policy would not have been n/a issued according to the correct age of the insured, the policy would not have become effective or would have ceased prior to the acceptance of the premium, then the liability of the insurer shall be limited to the refund of the premium paid for the period not covered by the policy. Incontestability § 38.2-5209 The provision contains specific incontestability language for long-term care insurance. n/a Unintentional Lapse 14 VAC 5-200-65 A 3 The policy must specify an additional 30 days for an unintentional lapse of coverage. n/a

11BOptional Provisions Change of Occupation § 38.2-3504 1 n/a Misstatement of Age § 38.2-3504 2 n/a Other Insurance in this § 38.2-3504 3 Company n/a Individual Long-Term Care Insurance (LTCI) (FORMS) Virginia 1st Edition July 2001 Page 5 of 9 Updated: April 2020 Review Requirements Checklist INDIVIDUAL LONG-TERM CARE INSURANCE (LTCI) (FORMS)

REVIEW REQUIREMENTS REFERENCES COMMENTS PG # Insurance with Other § 38.2-3504 4 Companies n/a Insurance with Other § 38.2-3504 5 Companies n/a Unpaid Premium § 38.2-3504 7 n/a Conformity with State Statutes § 38.2-3504 9 Must use “resides” language. n/a Illegal Occupation § 38.2-3504 10 n/a Intoxicants and Narcotics § 38.2-3504 11 Intoxicants and Narcotics n/a

12BProhibited Provisions Subrogation § 38.2-3405 A No policy shall contain a provision regarding subrogation of any person’s right to recovery for personal injuries from a third person. n/a Liability Insurance § 38.2-3405 B Benefits may not be reduced due to benefits payable due to benefits provided by a liability insurance contract. n/a Workers’ Compensation § 38.2-3405 D The statute discusses exceptions to exclusions due to benefits payable under workers’ compensation. n/a

13BProhibited Provisions § 38.2-5203 Specified provisions prohibited in a long-term care policy. n/a Prior Institutionalization § 38.2-5205 A Prior institutionalization may not be a requirement to receive benefits. n/a Minimum Standards for Home 14 VAC 5-200-90 The minimum standards include prohibited exclusions and restrictions regarding Health Care home health care benefits. n/a Replacement Prohibitions 14 VAC 5-200-190 Preexisting conditions and waiting periods may not be used in replacement policies. n/a LTC Policy Requirements Limitations and Exclusions 14 VAC 5-200-60 B Limitations and Exclusions n/a Duration of Benefits § 38.2-5200 Coverage must be provided for a minimum of 12 months. n/a Policy Definitions § 38.2-5200 Certain terms defined. 14 VAC 5-200-50 n/a

Refund of Premium for § 38.2-5202.1 Provides for the termination of the policy by the insured and for cancellation of n/a Cancellation or Termination of the policy by the insurer, except when coverage is for the duration of life and Policy premium is a single installment payment. Preexisting Conditions § 38.2-5204 Defines look-back period and limitation period for preexisting conditions. n/a Preexisting Condition 14 VAC 5-200-70 D If policy includes limitations due to a preexisting condition, such limitations must Limitations be included labeled as “Preexisting Condition Limitations.” n/a Limitations or Conditions on § 38.2-5205 B Permissible benefit triggers and requirements. Eligibility for Benefits 14 VAC 5-200-187 n/a Individual Long-Term Care Insurance (LTCI) (FORMS) Virginia 1st Edition July 2001 Page 6 of 9 Updated: April 2020 Review Requirements Checklist INDIVIDUAL LONG-TERM CARE INSURANCE (LTCI) (FORMS)

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14BOutline of Coverage § 38.2-5207 1; The statute requires that an outline of coverage be provided to the insured. The 14 VAC 5-200-200 statute also specifies the information that should be included in the outline. n/a Nonforfeiture Benefit § 38.2-5210 Offer made to the policyholder. Refer to the regulation for specifics. Requirement 14 VAC 5-200-185 B n/a Contingent Benefit Upon Lapse § 38.2-5210 If the offer of the nonforfeiture benefit is declined, the contingent benefit upon 14 VAC 5-200-185 C lapse shall be provided. n/a Definitions 14 VAC 5-200-40 n/a Extension of Benefits 14 VAC 5-200-60 C n/a

Signed Acceptance for Riders 14 VAC 5-200-70 B All riders and/or endorsements that are added to a policy after the date of issue n/a and Amendments that reduces, restricts, or eliminates benefits in the policy will require signed acceptance. Also, where a separate premium is charged for a rider or endorsement, the premium will be set forth in the policy, rider, or endorsement. Usual, Customary, and 14 VAC 5-200-70 C The term must be defined If benefits are based on usual, reasonable and Reasonable Defined customary charges. n/a Required to Offer Inflation 14 VAC 5-200-100 A Protection n/a LTC Personal Suitability 14 VAC 5-200-175-C 2 The LTC personal suitability worksheet must be submitted with the policy. Worksheet n/a Right to Reduce Coverage and 14 VAC 5-200-183 The policy shall include a provision that allows the policyholder to reduce Lower Premiums coverage and lower the premium. n/a

15BDisclosures

16BTax-qualified LTCI § 38.2-5207 4; A tax-qualified plan must be definitively identified as such and prominently 14 VAC 5-200-70 H disclosed. n/a

17BNonqualified LTCI 14 VAC 5-200-70 I A non-tax-qualified plan must be identified as such. n/a

18BApplies to policies where 14 VAC 5-200-70 A 2 The policy shall include a clear and prominent statement in bold type and all premiums can be revised capital letters that the premium rates may be increased. n/a

19BNotice of premium rate 14 VAC 5-200-75 D Any reference to a premium increase shall disclose that notice of premium n/a increase increase shall be at least 75 days prior to the implementation of premium rate schedule.

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REVIEW REQUIREMENTS REFERENCES COMMENTS PG # Policies that include issue ages 14 VAC 5-170-150 E 1 Any policy marketed to persons age 65 or older must contain a notice that of 65 or higher discloses that the policy is not a Medicare supplement policy or certificate. n/a

20BRates § 38.2-316 Complete one of the following checklists as indicated: n/a FOR NEW LONG-TERM CARE INSURANCE (LTCI) RATES n/a FOR REVISION TO LONG-TERM CARE INSURANCE (LTCI) RATES n/a

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I hereby certify that I have reviewed the attached individual long-term care filing and determined that it is in compliance with the individual long-term care checklist. Digitally signed by Barbara Caruso Signed: Barbara______Caruso Date: 2021.06.08 09:55:36 -04'00'

Name (please print): ______Barbara Caruso

Company Name: ______Knights of Columbus

Date: ______6/8/2021 Phone No: (203 ) ______752-4364 FAX No: (203 )______752-4018

E-Mail Address: [email protected]

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