Adoption of NAIC Model Bulletin

Eleven states have adopted the NAIC Model Bulletin on the use of AI by insurers, in part or in whole, as of: April 22, 2024.

In order of adoption:

• Alaska, February 1, 2024, Bulletin B 24-01: No notable changes

• New Hampshire, February 20, 2024, Docket #INS 24-011-AB:

  • Strongly encourages development of verification and testing methods to identify errors and limit unfair discrimination (as opposed to simply encourages)

  • Updates “bias analysis and minimization” in reference to data management practices to “unfair bias analysis and minimization”

• Nevada, February 23, 2024, Bulletin 24-001: No notable changes

• Connecticut, February 26, 2024, Bulletin MC-25: 

  • Insurers must complete annual Artificial Intelligence Certification that attests to compliance with the Bulletin

• Vermont, March 12, 2024, Insurance Bulletin 229: No notable changes

• Illinois, March 13, 2024, Company Bulletin 2024-08: No notable changes

• Rhode Island, March 15, 2024, Insurance Bulletin 2024-03: No notable changes

• Pennsylvania, April 6, 2024, Notice 2024-04: No notable changes

• Kentucky, April 16, 2024, Bulletin 2024-02: 

  • Clarifies that the guidelines in the bulletin are non-binding and softens the overall tone, using phrases like “the Department recommends,” “the Department advises,” or “controls would ideally address” 

• Maryland, April 22, 2024, Bulletin 24-11:

  • Extends scope from insurers to include nonprofit health service plans, HMOs, and dental plan organizations

• Washington, April 22, 2024, Technical Assistance Advisory 2024-02: No notable changes