Pre-Existing Medical Conditions (PEMCs) (3) 

YOUR COMPLIANCE MATTERS:   Pre-Existing Medical Conditions (PEMCs) (3) 

Relevance:                 All firms offering Travel Insurance. 

Action required:       Update signposting records and staff training 

Last year, some changes were introduced to assist consumers with obtaining suitable travel insurance arrangements if they were living with pre-existing medical conditions (PEMCs) and we pointed out that if you offer and distribute retail travel insurance, the new rules apply to you, as well as any of your Appointed Representatives that does the same.

 The FCA position on this is that “Firms that sell travel insurance will have to signpost consumers to a directory of specialist firms that provide this type of insurance.”

As previously indicated, such firms are required to include details of a “Medical Cover Firm Directory” on its website where it markets travel insurance.

In this respect, there are now two directories available that meet the FCA criteria;

·      On 08 October 2020, the Money and Pensions Service (MaPS) Directory was confirmed; and now

·      On 27 January 2021, BIBA (British Insurance Brokers Association) Directory was also confirmed.

As we have previously indicated, all firms that offer retail travel insurance must include details of at least one of the confirmed directories on their websites, in accordance with the timing requirements in ICOBS 6A.4.3R.

The information required must:

(a) be provided in a prominent, clear and accurate manner; and

(b) include the contact details of the medical cover firm directory, including its telephone number and a link to its website;

These obligations apply 30 calendar days from the date on which the firm becomes aware (or ought reasonably to have become aware) of a publicly available directory that meets the FCA’s requirements of a medical cover firm directory.

So, the MaPS details should already be used and now BIBA’s can be added or used instead:

We are told that:

·      Consumer enquiries about the BIBA directory can be made to BIBA’s call centre on 0370 950 1790, which is available Monday to Friday, 9am to 5.30pm.

·      Firms that want to be included on the directory, whether or not they are a member of BIBA, can contact BIBA’s Find Insurance Service Manager, Kirsty Fell, at fellk@biba.org.uk or 07920 577699.

From 26 April 2021, firms must signpost certain customers with PEMCs to a Medical Cover Firm Directory.

Remember also, that staff will need to be aware of these signposting requirements and be able to point customers in the right direction.

We will keep you advised of developments in this area but remember, we can also assist you with any aspect of appropriate communications and website wording or relevant staff training, if you require it. As ever, all you need to do is ask us.