Insurance Regulatory and Development Authority of India
Ref. No:– | Date:28-04-2022
Guidelines on Group Insurance Products under Health Insurance Business and other operational matters
On comprehensively examining the extant framework governing the administration of group health insurance products, in order to protect the interests of the insuring public and the insured members of group schemes, it is proposed to issue suitable guidelines on Group Insurance Products under Health Insurance Business and other operational matters.
Accordingly, an exposure draft on the above proposed guidelines are herewith published.
All stakeholders are requested to forward their comments/suggestions on the within referred exposure draft by 13th May 2022 in the attached format to the email id k.srinivas@irdai.gov.in
D V S Ramesh
General Manager (Legal and Health)
To
All Life, General and Health Insurers
Reg: Exposure Draft on Group Insurance Products under Health Insurance Business and other operational matters
Group Insurance facilitates enhancing the access to insurance to both formal and informal sectors of the society. If operated prudently, it offers the advantage of beneficial coverage at moderate cost. With a view to rationalise and standardize the administration of group health insurance products so as to protect the interests of the insuring public and the insured members of group schemes, the following guidelines are issued by virtue of the powers vested under Regulation 7(a) of IRDAI (Health Insurance) Regulations, 2016(HIR, 2016) read with Section 34(1) of Insurance Act, 1938 for compliance by all Insurers carrying on group health insurance business.
This Circular supersedes the following as far as they pertain to group policies under Health insurance:
a) Guidelines on Group Insurance Policies (Ref:015/IRDA/Life/Circular/GI Guidelines/2005 dated July 14th, 2005).
b) Clarification on Guidelines on Group Insurance Policies (Ref: IRDA/Life/Cir/Misc/001/01/2011 dated January 4th, 2011).
c) Chapter V of Consolidated Guidelines on Product Filing in Health Insurance Business (Ref: IRDAI/HLT/REG/CIR/194/07/2020 dated 22ndJuly, 2020).
Definitions:
1. For the purpose of these Guidelines:
a) “Certificate of Insurance” means documentary evidence issued by the insurer to a member of a group insurance policy in support of giving insurance coverage as per the requirements of the master policyholder.
b) “Master Policyholder” means a person to whom a group insurance policy is issued by an insurer extending insurance coverage for the members of the group.
c) “Employer-Employee Group” means group where an employer-employee relationship exists between the master policyholder and the member, in accordance with the relevant laws.
d) “Non-Employer-Employee Group” means group other than employer-employee, where a clearly evident relationship between the member and the group policyholder, for services other than insurance, exists.
e) “Large Group” means group extending coverage to over and above 500 members
f) All words and expressions used and not defined in these Guidelines but defined in the Insurance Act, 1938 (4 of 1938), as amended from time to time, the Insurance Regulatory and Development Authority Act, 1999 or in any of the Regulations/Guidelines made thereunder shall have the meanings respectively assigned to them in those Acts/Regulations/Guidelines.
General
2. A group shall not be formed with the main purpose of availing insurance. Negotiating group rates and then forming a group is not permitted.
3. As the primary purpose of any health cover is to meet the treatment costs or to manage the life style on diagnosis of a critical illness, no Insurer is permitted to offer any indemnity or benefit based credit linked group health products, except for coverage of accidental death and disability in respect of policies issued under Personal Accident.
Provided existing Credit Linked Group Health Products shall be withdrawn by XX (Date)/ XX/ (Month)/ XXXX (Year).
Provided further, the existing credit linked group health policies already issued shall be continued till the expiry of policy contract.
Group Size and Term
4. Subject to the minimum number prescribed in Regulation (7) of HIR, 2016, every Group Health Insurance Product shall specify the minimum group size for offering Group Health Insurance Policy.
4.1. No Group Insurance policy shall be issued to a group whose size is less than the minimum stipulated in the product expecting that the group would reach that size over a period of time.
4.2. Group size for micro insurance groups shall be in accordance with the norms specified in IRDAI (Micro Insurance) Regulations 2015, as may be amended from time to time.
5. The policy term of every group insurance policy shall be as stipulated in HIR, 2016. Where the Group Insurance Policy is open for the entry of members at periodic intervals say every month or every quarter, though the duration of the Group Policy may be beyond the policy term stipulated in HIR, 2016, the insurance coverage for every member of the group insurance policy shall not exceed the maximum policy term stipulated in HIR, 2016.
6. Subject to maintaining the minimum group size and the maximum policy term stipulated in HIR, 2016, Insurers may issue multiple group insurance policies in tranches to the Master Policyholders for providing insurance coverage to the new members on an ongoing basis.
7. In terms of HIR, 2016, Life Insurers may also offer Group Health Products for a term of one year. However, policy terms and conditions shall also be subject to IRDAI (Linked Insurance Products) Regulations 2019 and IRDAI (Non-Linked Insurance Products) Regulations 2019.
Provided that as per Regulation 3 (b) of IRDAI (Health Insurance) Regulations 2016, Life Insurers shall not offer indemnity based Group Health Products.
Underwriting and Pricing Aspects
8. All insurers offering group insurance should have a Board approved group insurance underwriting policy. The policy should specify the manner in which its risk and costs are analyzed and factored into the premium cost. All risk factors per unit of coverage such as individual, family, group floater, etc., should be separately analyzed and priced. Past experience and future exposures should also be critically analyzed for “Large Group”.
9. The underwriting and the rate review process of the group policies at the time of renewal should consider the member entry and exit patterns from the group in order to address the possibility of adverse selection, moral hazard or fraud.
10. The insurer shall ensure issuance of certificate of insurance (CIS) to the members of the group, who are insured. The certificate of insurance shall include the schedule of benefits, period of cover, the premium paid, the frequency and premium payment term. It should have important terms and conditions including waiting periods, sub limits, deductibles, co-pay and exclusions. It shall also detail the procedure to be followed to register a claim with the insurer including complete details of the insurer where the claim should be registered.
11. A master policy is to be issued to the group. The insurers may endeavour that the same is made available by the master policyholder for guidance of the members covered.
12. Pricing is to be made based on sound actuarial principles, supporting data considering all the relevant aspects of pricing such as morbidity experience by gender, by age group, by occupation, by group size etc, expenses, terminations, profit margin apart from any other relevant criteria.
13. For innovative covers, Insurers shall base the pricing prudentially on the relevant morbidity experience which reflects the future expected experience from such innovative covers apart from considering other parameters.
14. Insurers shall review the group insurance policies offered including pricing every year.
15. Insurers must justify the rates and terms offered to any group to the Authority, if called upon to do so. All discounts should be based on valid underwriting considerations, taking into account the loss experience of the group, the expenses including commission that may be incurred / payable. Discounts and Loadings offered shall be based on objective criteria with appropriate justifications.
16. In case of group policies issued to promoter group companies/ subsidiary companies or other related party companies, the premium rates charged vis-à-vis the coverage granted shall be placed before the risk management committee of the Insurance company on half-yearly basis for a review.
Entry and Exit norms
17. Master Policyholder and General / Heath Insurer concerned shall facilitate the migration/portability as per the group scheme rules; the applicable norms stipulated in HIR, 2016 and the guidelines issued by the Authority from time to time.
18. Though entry into or exit from the group may go on continuously, entry into the group insurance policy for individual members will be either from a well-defined date such as the next anniversary of the policy or from the first of the following month or from a clearly identifiable date, subject to receipt of premium in time.
19. Insurance will cease as soon as a member leaves the group except where it is agreed in advance to continue the benefit even after the member leaves the group.
Employer – Employee groups
20. Where an employer buys a group insurance policy for its employees, the employer may be treated as the master policyholder with the employees being treated as the beneficiaries. In such cases, the employer shall issue confirmation of insurance protection to individual employees with clear reference to the group insurance policy. The reimbursement claims of individual persons insured thereunder may be paid through the employer.
Non-Employer-Employee groups
21. In non-employer-employee cases, the individual group member would be treated as the insured beneficiary and the master policyholder will only be the holder of the policy.
22. The Insurer may provide the facility to the master policyholder to issue certificates of insurance as stated in clause 10 herein on behalf of the Insurer to persons insured under the group, provided the underwriting guidelines for acceptance or rejection of such a risk do not require use of subjective judgment. The insurer should provide software to the master policyholder which will review acceptance and print the certificate of insurance. It is advised only simple policies be sold to such groups where underwriting is not complicated.
22.1 Under all circumstances the insurer shall be responsible for the certificate of insurance issued by a master policyholder.
23. The insurer may utilize the services of the master policyholder in facilitating the intimation and settlement of a claim. However, subject to clause 24 herein the insurer shall ensure that the claim payment is made in the name of the insured member or his/her nominee.
24. In case of lender-borrower group insurance schemes offered by insurers, the claim payment to master policyholder is allowed subject to the provisions and procedure set out in Annexure A to this Circular.
25. The insurer shall be held responsible to the group members insured, in respect of the group policy in case of failure of the master policyholder to account for the business to the insurer, if the insured group member can prove that he had paid the premium and secured a proper receipt leading him to believe that he was duly insured as part of the Group.
26. The Insurer, under an agreement with the master policyholder, may leverage on the existing infrastructure, if any, for better administration of the scheme with respect to the following services.
26.1. data management
26.2. collection of premium
26.3. issuance of Certificate of Insurance and
26.4. claims documentation
27. The Insurer may make payments directly to the Master Policyholder, subject to clauses 29 and 30 herein, for the services rendered as stipulated in clause 26 above under an agreement not exceeding the limits given below:
27.1. For data Management: Rs. 20/- per member per annum
27.2. Premium Collection: Rs. 10/- per member per annum
27.3. Issuance and delivery of certificate of Insurance: Rs. 20/- per member subject to a minimum of Rs. 500/- for a scheme. The issue of duplicate certificate of Insurance shall not be done by the Master policyholder;
27.4. Claims documentation: Rs. 15/- per claim
28. No payments, other than what is prescribed at clause 27 above, shall be made by insurers to the agent or intermediary or master policyholder towards the administration of Group Insurance scheme. The Master Policyholder shall not collect by way of Insurance premium or in any other form from the members of a group, any amount higher than the amount charged by or paid/payable to the insurer for such insurance.
29. The total payments to the master policyholder, as per clause 29 hereinabove:
29.1. shall not in any case exceed the 20% of the commission payable as per the IRDAI (Payment of Commission or Remuneration or Reward to Insurance Agents and Insurance Intermediaries) Regulations, 2016, in the respective lines of business.
29.2. shall not exceed for each of the services individually, the rated proportion to the overall limit of 20% of the commission payable as per the IRDAI (Payment of Commission or Remuneration or Reward to Insurance Agents and Insurance Intermediaries) Regulations, 2016.
30. Further, if the master policyholder is an insurance intermediary under the group policy, since the functions referred at clauses 26.1, 26.2 and 26.4 above form part of the obligations of an intermediary, no payments be made and no expense be reimbursed to the master policyholder or any other entity in respect of such functions. In such cases, only with respect to services referred in clause 26.3, the services of a master policyholder may be utilized and payment may be made as stipulated at clause 27.3 above, provided the master policyholder himself is carrying out the same.
Servicing Norms to the Insurers and Master Policyholders
31. All group health insurance policies having named beneficiaries should have ID cards issued to the beneficiaries to enable them obtain cashless service, wherever applicable.
32. Master Policyholder shall attach, a complete list of the persons insured thereunder. Where this is not feasible, in view of the large size of the group, a clear reference shall be made to a list of persons insured which is maintained in the books of the master policyholder that cannot be subsequently altered and made available to the Insurer as and when required.
33. Unnamed policies may also be issued by insurers provided the group has non-tamperable registers or records or procedures to identify the member insured / covered. The registers, records or the procedures shall be subject to inspection by the insurers at any time.
34. The insurer and the concerned Insurance Agent or Insurance Intermediary, shall take all such initiatives to ensure that a group policy is administered fairly to protect the interests of the beneficiary members or potential consumers or to the public at large.
Disclosures
35. The Master Policyholder’s role as facilitator in offering a group cover and facilitating insurance services including claims needs to be clearly spelt out between the group and insurer as part of the Terms and Conditions.
36. As part of the terms and conditions of the Group Insurance policy, the Insurer shall put in place enabling provisions to enable the beneficiary or the insured member to raise grievances directly either with the insurer or with appropriate Grievance redressal mechanism. The granular details in this regard shall be part of the terms and conditions mentioned in the Certificate of Insurance.
37. The premium charged and benefits admissible to each member of the group shall be clearly specified in the group policy and the master policyholder shall not vary the premium or benefits with regard to the individual members.
Additional Norms on Group Travel Insurance policies
38. Group Policies issued towards domestic and overseas travel coverage shall also comply with the following norms:
38.1. Premium shall be received not more than 90 days in advance to the date of commencement of the risk covered in case of domestic travel or along with the ticket while purchasing the travel tickets whichever is earlier.
38.2. Covers towards overseas travel may be issued at any time.
38.3. Where policies are offered through any travel agency or portal, the following norms shall be complied:
38.3.1. Insurers are responsible to ensure an informed choice to the persons to be insured and ensure compliance to Regulation 6 of IRDAI (Protection of Policyholders’ Interests) Regulations, 2017.
38.3.2. The Name of the Insurance Company which is offering the travel insurance cover, the amount of the premium that shall be collected towards travel insurance cover shall be specifically disclosed as the cost of travel cover, at the time of opting to buy a travel insurance cover. Rate of tax that is applicable to the premium shall be also separately specified.
38.3.3. Insurers shall ensure that any portal or App providing the travel insurance coverage shall not pre-select the option of buying the travel cover as a default option.
38.3.4. The prospect shall be able to specifically choose whether or not to buy the coverage.
38.3.5. Where selected to buy, an option shall be provided for opting out or de-selecting the option before concluding the transaction.
38.3.6. There shall be a provision to let the person to be insured buying a travel cover go through the benefits, terms and conditions offered under the travel insurance cover on the screen itself and consent shall be obtained in the form of selecting a radio button by the prospect / policyholder in confirmation of having read and understood the terms and conditions.
38.3.7. In order to ensure that every travel policy offered is in compliance with these norms, there shall be a clause in the agreement entered with the master policyholder and in the terms and conditions of the group policy along with a provision to cancel the group policy arrangement if the master policyholder is not adhering to the norms specified.
38.4. Insurers shall put in place procedures to verify that at least once in a period of three months the travel policies offered are complying with the above norms.
Other norms
39. The insurer shall conduct inspection of the books and records of the mater policyholder of non-employee–employer group at least once a year or require a certificate of such compliance from the auditors of the master policyholder, at least once a year to ensure compliance with these Guidelines.
40. An insurer who is engaging insurance intermediaries for sale of its group products shall require such Intermediary to file certificates at least once a year, from an independent auditor at the expense of the intermediary, confirming compliance with Section 64VB relating to collection and credit of premium, IRDA (Insurance Advertisements and Disclosures) Regulations, 2000, and IRDAI (Protection of Policyholders’ Interests) Regulations, 2017.
41. Subject to the norms specified at Clause II of Chapter IV of Consolidated Guidelines on Product filing in Health Insurance Business (Ref: IRDAI/HLT/REG/CIR/194/07/2020) dated 22nd July, 2020, insurance products offered by General and Health Insurers for schemes sponsored by the State and Central Governments shall adhere to the conditions of the scheme as laid down by the Government.
42. This has the approval of the competent authority.
General Manager (Health)
Encl:
Annexure A
Annexure B
Annexure A
Instructions on Claim Processing for Group Policies in respect of Health Insurance Business under Lender – Borrower Group Schemes
1. These Instructions are applicable to Group Insurance Polices / Schemes covering Lender-Borrower groups in respect of Health Insurance Business and administered by the following entities as Master Policyholders, subject to the conditions mentioned vide 2 herein:
1.1. Reserve Bank of India (RBI) Regulated Scheduled Commercial Banks (including Co-operative Banks).
1.2. NBFCs having Certificate of Registration from RBI.
1.3. National Housing Bank (NHB) Regulated Housing Finance Companies.
1.4. National Minority Development Finance Corporation (NMDFC) and its State Channelizing Agencies.
1.5. Small Finance Banks regulated by RBI
1.6. Mutually Aided Cooperative Societies formed and registered under the applicable State Act concerning such Societies.
1.7. Microfinance companies registered under section 8 of the Companies Act, 2013.
1.8. Any other category as approved by the Authority.
2. The schemes administered by the above entities are subject to the following conditions:
2.1. The Individual Member of the Group Insurance Scheme / Policy of Health Insurance Business shall specifically authorise the Insurance Companies to make the payment of Outstanding Loan Balance amount to Master Policyholder by deducting from the claim proceeds payable on the happening of the contingent event covered by the Group Insurance Scheme / Policy.
2.2. The terms and conditions of the Group Insurance Scheme/ Policy contract of the respective Group Insurance Scheme/ Policy shall have an enabling clause both for obtaining the said Authorisation from the Individual Members of the Group and also for allowing the Insurers to make claim payments in favour of the Master Policyholder to the extent of the Outstanding Loan Balance.
2.3. The Insurers shall ensure that the specific authorization is in consideration of;
2.3.1. having received a loan or
2.3.2. the existing outstanding loan.
2.4. The Authorization shall be obtained from the Member Insured at the time of joining the group insurance scheme/policy or at a later date.
2.5. In respect of existing policies/schemes, the Insurer and the Master Policyholder may mutually agree and pass an endorsement to the existing group insurance policies as specified under Clause 2.1 after specifically obtaining Authorisation from the Individual Members of Group Insurance as in Clause 2.2.
2.6. The payment of claim amounts to the extent of Outstanding Loan Balance amount may be paid in accordance to these Guidelines only after specifically obtaining the Authorization from the Individual Member of the Group Insurance Scheme/Policy.
3. The Insurance Companies shall obtain from the Master Policyholder, a Credit Account Statement in respect of the Insured Member to whom/whose nominee or beneficiary the claim monies are payable on the happening of the insured contingency with inter alia, the following details:
3.1. Name of the Group Master Policyholder.
3.2. Group Master Policy Number.
3.3. Name of Insured Member.
3.4. Date of Commencement of Risk.
3.5. Sum Assured for which the Member of the Group Insurance Policy was insured.
3.6. Original Amount of Loan.
3.7. Particulars of the recoveries made by the Master Policyholder towards the Loan.
3.8. Outstanding Loan Balance as on the date of happening of the contingent event covered.
3.9. Balance Claim Amount (difference between the sum assured referred under 3.5 above and Outstanding Loan Balance referred under 3.8 above) payable to the nominee / beneficiary of the deceased member in case of death claim, or to the insured member on the happening of other contingent event.
4. The Credit Account Statement submitted by the master policyholder, as mentioned in 3 above shall also have the declaration that the information / details furnished in the Credit Account Statement are verified for accuracy.
5. Insurance Companies shall settle the Claim on the happening of the contingent event covered under the Group Insurance Scheme/Policy after obtaining, apart from the usual claim requirements, the Credit Account Statement to the extent of
5.1. Outstanding Loan Balance amount in favour of Master Policyholder of the Group Insurance Scheme/Policy, as mentioned in 3.8 above.
5.2. Balance Claim amount if any (as mentioned in 3.9 after deduction of the Outstanding Loan Balance) directly in favour of nominee / beneficiary of the deceased member of the Group Insurance Scheme/Policy as the case may be.
6. The amount payable to the Master Policyholder shall under no circumstance be more than the Outstanding Loan Balance of the Member of Group Insurance as mentioned in 3.8 of the Credit Account Statement.
7. Where the Claim Discharge Form of the Insured Member / Nominee / Beneficiary is obtained through the Master Policyholder, the Insurer shall take a Certification either in the Claim Discharge Form or in a separate format from the Master Policyholder that the Insured Member / Nominee / Beneficiary who had submitted the Claim Discharge Form is the same person who has been registered by the Master Policyholder as the Insured Member / Nominee / Beneficiary under the Group Master Policy.
8. Complete details of the claim amount settled, the remittances made to the Master Policyholder towards Outstanding Loan Balance and the balance claim amount payable to the Insured Member / Nominee / Beneficiary shall be communicated by the Insurer directly to the Insured Member / Nominee / Beneficiary.
9. Where the entire claim proceeds are adjusted towards Outstanding Loan Balance, a communication shall nevertheless be directly forwarded by the Insurer either to the Insured Member or to the Nominee / Beneficiary, as the case may be, with complete details of the total amount of claim settled and the amount remitted to the Master Policyholder towards Outstanding Loan Balance.
10. The Insurers shall have in place an enabling clause in Terms and Conditions of the Group Insurance Scheme / Policy that they shall audit or cause an audit into the accuracy of the Credit Account Statements of the insured members in respect of which claims were settled on the completion of every financial year and every Insurer shall audit or cause an audit into the accuracy of the Credit Account Statements in respect of the deceased group insured members furnished by the Master Policy Holder.
11. However, notwithstanding the above clause as part of the terms and conditions of the group insurance contract, the Insurers may also delegate the responsibility of the audit and require the Master Policyholders to audit or to cause an audit into the accuracy of the Credit Account Statements of the insured members in respect of which claims were settled on the completion of every financial year and shall obtain a certification from their respective Internal / Statutory Auditors that the Outstanding Loan Balance being shown in the ‘Credit Account Statement’/ ‘Claim Discharge Form’ is correct and reflecting the balance as per the conditions governing the Credit Account / Loan Account.
12. In the event of any discrepancy found in the audit report of such Credit Account Statements, the onus of settling the difference amount, if any, to the Insured Member / Nominee / Beneficiary of the Group Insurance Scheme/Policy, as the case may be, rests with the Insurer.
13. The Insurer is responsible to redress the specific grievances of the Insured Member / Nominee / Beneficiary that may arise either during policy term or after settlement of the claim.
14. The Insurers shall obtain the documentary evidence to establish that the entities referred from 1.1 to 1.8 above are registered with the appropriate authority or under applicable legislation and continue to be eligible.
15. The Insurers shall submit yearly compliance certificate from their respective statutory auditors in the prescribed proforma attached as Annexure-B. The certification in the prescribed proforma shall be submitted in respect of the entire group insurance portfolio of the Insurer and be filed with the Authority within 90 days of the expiry of the respective financial year.
Annexure B
Frequency: Yearly
Name of Insurer:
Information for the Financial Year ending _______
Form: GHCLCC
| I | Total Number of Non Employer-Employee Group Insurance Schemes/Policies | ||||||||||
| II | Total Number of Group Insurance Schemes/Policies under Lender Borrower Schemes | ||||||||||
| Sl
No |
Where the Master Policy holder is: | No of Schemes | No of Members Insured | Where claims settled in full and payment made in favour of MPH | Where claims are settled in part and payment made in favour of MPH | Where claims are settled in full and payment made in favour of Nominee / Beneficiary. | |||||
| To the MPH | To the Nomine | ||||||||||
| No of Clai-ms | Be-nefit Amo-unt | No of cla-ims | Ben-efit Am-ount | No of Cla-ims | Ben-efit Am-ount | No of Clai-ms | Be-nefit Am-ount | ||||
| 1 | RBI Regulated Scheduled Commercial Banks with RBI regulated Scheduled Banks (including Co-operative Banks). | ||||||||||
| 2 | NBFCs having Certificate of Registration from RBI. | ||||||||||
| 3 | NHB Regulated Housing Finance Companies. | ||||||||||
| 4 | NMDFC and its State Chann-elizing Agencies | ||||||||||
| 5 | Small Finance Banks regulated by RBI | ||||||||||
| 6 | Mutually Aided Coop Societies | ||||||||||
| 7 | Microfinance Companies registered under Section 8 of Companies Act, 2013. | ||||||||||
| 8 | Any other entity as approved by the Authority | ||||||||||
(1) It is certified that in respect of all the group Insurance schemes where claims are settled (whether for full claim amount or partial claim amount) and payments are made in favour of the master policyholder, the insurer has:
a. obtained specific authorization from the individual members of the group insurance scheme / policy in compliance to Clause 2.1 of the Annexure A;
b. enabling clause was there in the terms and conditions in compliance to clause 2.2 of the Annexure A;
c. obtained a credit account statement from the Master Policy Holder in compliance to Clause: 3 of the Annexure A.
(2) In respect of the following group schemes where payments are made (whether in part or in full) in favour of Master Policyholders, non-compliance is observed as mentioned hereunder:
(3) In respect of the Certification furnished for the financial year ending 31st March, 20XX(Note: Specify the year), in addition to the above, the statutory auditors shall also certify the following:
a. In respect of the following cases the insurer complied with Clause 10 or Clause 11 of the Instructions.
i. Number of Group Insurance Schemes:______
b. In respect of the following cases the insurer has not complied with Clause 10 or Clause 11 of the instructions.
i. Number of group insurance schemes where non-compliance has been observed: _____
It is certified that the above information is furnished after examining the relevant records of the insurer. The information furnished is correct.
Signature of the Statutory Auditor#
Place:
Date:
Seal
#In case of engaging more than one statutory auditor, the insurers may submit the above certification from at least one of the auditors.
Format for furnishing comments on ‘Guidelines on Group Insurance Products under Health Insurance Business and other operational matters’
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