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OIR CCRC Coronavirus Alert #5 - April 13, 2020

Joel L. Anderson, Chair | Steve Bahmer, President/CEO

1812 Riggins Rd | Tallahassee, FL 32308 | P: (850) 671-3700 | F: (850) 671-3790

Continuing Care/Life Plan Coronavirus Alert #5

Guidance on Filing Contract Changes or a Contract Addendum with OIR  If you need to make changes to your residency agreement (otherwise known as a contract) because of the COVID-19 pandemic, the process has not changed. The revised contract or addendum should be filed with the Office of Insurance Regulation by going to  

You must submit the contract changes or addendum as a “Forms-only Filing.” Submit the addendum/contract in the “Form to be Reviewed Component.” If you would like flexibility within the form for different time frames for payment of the balance of the entrance fee or some other provision in the contract, you must bracket that portion of the form and include a second document titled “Statement of Variability” as a “Miscellaneous Component.” The purpose of a “Statement of Variability” is to describe in detail any section of a contract or addendum form that is bracketed/variable and provide all of the potential ranges/information that can be in the bracketed sections. In this example, the “Statement of Variability” must state that the number of days for final payment of the entrance fee and closing date specified in brackets in the revised contract or contract addendum, such as [30 days], will be 30 to 120 days depending on the circumstances of an individual prospective resident. This range of days is an example. You may want a shorter or longer time frame for extending final payment depending on what you are experiencing. 

Approval of contract changes on average take 13 days. It depends on the quality of the submission and whether the reviewer has questions.  

If you have questions, you may contact John Reilly (Deputy Director of Forms, Life and Health Product Review, Bureau of Life and Health Product Review) at (850) 413-5145 or Mr. Reilly is working from home, but he is checking his voice messages and emails. He is willing to answer questions and discuss the “Statement of Variability” concept.  

Presentation on Medicare/ Medicaid Extensions/Changes –
As Part of our daily call with members, on 4/7/2020, Boris Kushnir, Health Care Senior Manager, MSL CPA’s & Advisors delivered an excellent presentation on Medicare/Medicaid Changes Due to COVID-19 that you might want to share with your CFO. For a summary of his presentation, click here.  

Sample Letters to Residents Encouraging Staying in Place –
As the number of confirmed cases of COVID-19 increases statewide, continuing care/life plan communities are more forcefully discouraging residents from leaving the campus. For those communities without fencing and a security gate, it is difficult to determine resident compliance, but based on what we are hearing, residents are heeding the advice. Two members graciously gave us permission to share their latest communication with residents about this concern. Click here for sample notices.

Please retain this alert in a file on compliance with OIR requirements during the 2020 Coronavirus Public Health Emergency to use during your next OIR Examination/Triennial Audit in the event that there are related questions. 

For questions or more information, please contact Mary Ellen Early, Public Policy Liaison, via email or by phone at (386) 734-7681

1812 Riggins Rd, Tallahassee FL 32308
Phone: (850) 671-3700

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