Federal Advisory Committee on Insurance (FACI) 

COVID-19 Preparedness Subcommittee Recommendations 

June 2, 2021 

In December, the FACI approved several recommendations related to responses, 

emerging learnings, and making permanent several temporary actions. In addition, the 

Subcommittee was asked to refine its recommendations with respect to principles for life 

insurance premium relief. Specifically, we were asked to define the state of emergency 

that would precipitate such premium relief.

Further, to most comprehensively address this issue, the Subcommittee considered 

incorporating principles for property casualty coverages.

TOPIC #1: Definition of State of Emergency for Inclusion in Recommendation to 

Federal Insurance Office (FIO) About Principles for Life Insurance Premium Relief 

Context: Previously proposed principles did not define reference term “state of 

emergency” in their principles since we were essentially relying on the state to make the

declaration. We were encouraged by our FACI peers to add more specificity to the 

definition.

Proposal: 

1. A national public health emergency for which a Public Health Emergency is declared 

by the Secretary of Health and Human Services pursuant to the Public Health Service 

Act OR an Emergency Declaration is made by the President of the United States 

(pursuant to the Stafford Act or the National Emergencies Act); AND

2. The closure or significant curtailment of normal business activity for an extended

period in any state where accommodations are considered, pursuant to state orders

or other circumstances.
Federal Advisory Committee on Insurance (FACI)

COVID-19 Preparedness Subcommittee Recommendations 

June 2, 2021

Page 2

TOPIC #2: Recommendation to Federal Insurance Office (FIO) About Principles 

for Life Insurance Premium Relief

Context: Since previously proposed principles did not include recommendations for 

property and casualty insurance, this Subcommittee sought feedback from the American 

Property and Casualty Insurance Association (APCIA); however, we did not reach 

consensus. 

Therefore, we continue to propose the following principles and recommend working with 

our property and casualty insurance FACI peers to seek consensus as to how to edit these 

principles to be consistently applied for property/casualty. At present, there are no 

property and casualty insurance members on this Subcommittee.

Proposal:

If there is a state of emergency declared, the Subcommittee supports applying the 

following principles to the life insurance industry. 

1. For life insurance premium relief, 

a. Allowing premium payments up to a total of 90 days from the premium due 

date so that the policy is not canceled or lapsed;

b. Allowing reasonable repayment options for unpaid premiums;

c. Waiving any late premium payment fees or penalties;

d. Providing reasonable flexibility to policyholders or their beneficiaries 

regarding proof of claim; and

e. Providing policyholders the ability to make premium payments, report a claim 

or otherwise communicate with the policyholders’ insurer or producer 

electronically, or if in person, by maintaining safe social distancing standards.