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PA Insurance Department Guidance

The PA Insurance Department Chief of Staff issued the following guidance following Gov. Tom Wolf’s closure of all non-life-sustaining businesses:
Received March 20, 2020 – 5:07 PM in response to Gov. Wolf, Secretary Levine Provide Updated Guidance
Dear Colleagues,
As you may have seen, Governor Wolf has updated yesterday’s order to close all non-life sustaining businesses. The order now includes insurance among the businesses that may continue physical location operations, where necessary. The administration continues to recognize the essential functions that you provide that are critical to the well-being of your policyholders.
The Pennsylvania Insurance Department appreciates your willingness to engage with us in helping to mitigate the spread of COVID-19 in our communities. We applaud your efforts to move as many functions as possible out of your physical locations to assist in this regard. Please continue these actions and seek to employ social distancing techniques for those staff that are deemed essential to complete critical missions at the office.
Thank you for your understanding as guidance has evolved as the Commonwealth responds to the COVID-19 outbreak.
Stay safe,
Mike
Michael Humphreys | Chief of Staff
Pennsylvania Insurance Department
Previous Guidance
Received March 20, 2020 – 8:08 AM
Dear Colleagues,
The Department has been receiving numerous inquiries and concerns related to the impact of the governor’s announcement this afternoon ordering the closure of any physical locations of non-life-sustaining businesses. Governor Wolf is taking these steps to protect the health and safety of Pennsylvanians to the greatest extent possible, and it is imperative that all of us appreciate both the letter and the spirit of what the Governor is asking of us. Anything that can be done to protect the health and safety of Pennsylvanians should be done. As one of the largest employers in the Commonwealth, the insurance industry has a special responsibility not only to serve your policyholders, which is always the priority, but also to look out for the health and safety of your own employees. We know each of you is working to balance all of these priorities, as is the Commonwealth, and hope you take the Governor’s guidance as well as this further guidance in that regard.
The administration recognizes there are functions within many of your companies that must continue to ensure the critical needs of your policyholders are met. With that in mind, the announcement also put forth that special exceptions may be provided in limited circumstances. PID has been given oversight of applying that exceptions process for our regulated entities. To do so effectively, the Department offers the following guidance:
  • ANYTHING that can either be handled via telework or foregone all together for a period of time should be done so
  • ANYTHING that can be done to minimize the number of people needed in the office and/or the number of people needed in the office at one time should be done
  • Very limited personnel, such as very limited on site IT support to monitor network operability for a large workforce operating via telework or a minimal staff to process mail, where social distancing is inherently applied because of the small number of people anticipated to be present in the office, is acceptable without the need for processing of an individual exception
  • Services needed to directly support otherwise deemed life-sustaining functions are acceptable without the need for processing of an individual exception; if this is unclear, please discuss with the Department. In these cases, social distancing and other preventive measures should be applied to the greatest extent possible. (the only example of this the Department is aware of is an integrated delivery system providing child care for working medical professionals in their health system, where the child care center is located within the insurance entity’s offices)
  • If there are any truly essential functions that under no circumstances can be foregone or executed via telework, therefore requiring a significant number of employees in a given office space, PID will need to individually grant an exception. In order to obtain such an exception, regulated entities should email me at and outline:
    1. Why these functions are absolutely essential
    2. Why these functions cannot be completed via telework
    3. Processes the company has implemented or will implement immediately, such as social distancing, to prevent the potential spread of COVID-19 amongst employees
Thank you all for your commitment to working with the administration to prevent the spread of COVID-19 throughout our communities. We appreciate the level of communication with the Department thus far, and welcome further inquiries. As always, we will do our best to respond as quickly as we can while operating with finite resources. We do anticipate an influx of requests following this guidance and will do our best to respond timely, but ask your understanding as we work to execute a new process in a very short amount of time.
Sincerely,
Mike
Michael Humphreys | Chief of Staff
Pennsylvania Insurance Department
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