Relating to a biennial health coverage reference guide developed by the Texas Department of Insurance.

Contracts

• Plan Documents & Member Handbooks: Review definitions in your policy documents. While you do not need to amend contracts immediately, any definitions of "network," "deductible," or "appeal" that contradict the TDI guide will be vulnerable to legal challenge.
• Marketing Agreements: If you utilize third-party marketers for discount cards or limited-benefit plans, amend agreements to require adherence to the terminology established in the upcoming TDI guide.

Hiring/Training

• Customer Service Scripts: By Q1 2026, update call center scripts. Staff must be trained to respond to consumers referencing the guide (e.g., "The TDI guide says I have a right to X").
• Sales Training: Brokers and agents must be retrained to explain the difference between your products and the "comprehensive health insurance" baseline defined in the guide.

Reporting & Record-Keeping

• Internal Compliance Memo: Create a "gap analysis" document comparing your product's features against the guide’s descriptions of "scams" and "non-insurance products." This document will serve as your defense if a consumer alleges your product was sold under false pretenses.
• No New Filings: There are no new statutory reporting requirements to the state.

Fees & Costs

• No New Fees: The Legislative Budget Board anticipates no fiscal impact to the state, meaning no pass-through assessments to insurers are currently planned.