STORAGE NAME: h0655a.IBS
DATE: 3/7/2025
1
FLORIDA HOUSE OF REPRESENTATIVES
BILL ANALYSIS
This bill analysis was prepared by nonpartisan committee staff and does not constitute an official statement of legislative intent.
BILL #: HB 655
TITLE: Pet Insurance and Wellness Programs
SPONSOR(S): Tuck
COMPANION BILL: SB 1226 (DiCeglie)
LINKED BILLS: None
RELATED BILLS: None
Committee References
Insurance & Banking
17 Y, 0 N
Commerce
SUMMARY
Effect of the Bill:
The bill creates necessary regulatory statutes to facilitate the production of pet insurance policies for sale within
the state, encompassing various aspects such as defining pet insurance, establishing disclosure requirements, and
regulating the marketing and sales practices of wellness programs. It expands the definition of property insurance
to include coverage for pets, covering accidents and illnesses explicitly. Additionally, the bill imposes training
requirements for agents and brokers involved in selling pet insurance policies and outlines enforcement measures,
including penalties for violations under the Florida Insurance Code.
Fiscal or Economic Impact:
The bill may have an indeterminate fiscal impact on the private sector and state government expenditures.
JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
ANALYSIS
EFFECT OF THE BILL:
Expansion of Property Insurance Definition to Include Pet Coverage
This bill amends the definition of "property insurance" to explicitly include pet insurance coverage for accidents
and for illnesses or diseases of pets. It clarifies that property insurance may contain a provision for accidental
death or injury as part of a multiple peril homeowner’s policy, which is considered incidental to the property
insurance and is not subject to the provisions of the code applicable to life or health insurance. (Section 1).
Regulation of Sales Practices for Pet Wellness Programs
The bill defines unfair methods of competition and unfair or deceptive acts or practices related to the sales
practices for pet wellness programs. It prohibits pet insurance agents from marketing a wellness program as pet
insurance. If a wellness program is sold by a pet insurance agent, several conditions must be met, including:
The purchase of the wellness program cannot be a prerequisite to the purchase of pet insurance.
The costs of the wellness program must be separate and identifiable from any pet insurance policy sold by
the agent.
The terms and conditions of the wellness program must be distinct from any pet insurance policy sold by the
agent.
The products or coverages available through the wellness program cannot duplicate those available through
the pet insurance policy.
The advertising of the wellness program must not be misleading. (Section 2).
JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
2
Pet Insurance Definitions and Usage
The bill creates necessary regulatory statutes to facilitate the production of pet insurance policies for sale within
the state. The bill applies to policies issued to residents of the state, those sold or offered within the state's
boundaries, as well as policies delivered or issued for delivery in the state.
The bill defines pet insurance as coverage designed for accidents and illnesses or diseases of pets, facilitating
reimbursement for expenses linked to veterinary medical advice, diagnosis, care, or treatment, encompassing
prescribed medications. Additionally, it introduces definitions for various terms, including chronic conditions,
congenital anomaly or disorder, hereditary disorder, orthopedic condition, pet insurance policy, preexisting
condition, renewal, veterinarian, waiting period, and wellness program.
The bill mandates that if pet insurers incorporate the defined terms within a pet insurance policy, they must
adhere to the provided definition verbatim. Additionally, the pet insurer is required to ensure accessibility of these
definitions to policyholders. (Section 3).
Disclosure Requirements for Pet Insurance Policies
The bill requires pet insurers to disclose coverage exclusions for chronic conditions, congenital anomalies,
hereditary disorders, and preexisting conditions, along with any other applicable exclusions. Additionally, they
must disclose policy provisions limiting coverage, changes in coverage or premiums, and differentiate between the
underwriting company and the marketed brand.
Pet insurers must allow a 30-day review period for policyholders to return policies for a refund if unsatisfied,
provided no claims have been filed. They must also disclose the basis for determining claim payments, including
benefit schedules and fee limitations, and any required medical examinations before policy purchase.
Further, the bill requires pet insurers to clearly disclose waiting periods and their requirements to applicants. Pet
insurers must provide a summary of policy provisions and written disclosures including contact details for
regulatory offices and the insurer or agent. These disclosures are in addition to any other disclosures required by
law or regulation. (Section 3).
Preexisting Conditions, Waiting Periods, and Policy Renewals
The bill allows pet insurers to issue policies excluding coverage for preexisting conditions, provided that
appropriate disclosure is made to the applicant or policyholder, with the burden of proving the applicability of the
exclusion resting on the insurer. Additionally, pet insurers are permitted to impose waiting periods before the
effective date of a new policy, not exceeding 30 days for certain conditions,
1 with provisions for waiving the
waiting period upon completion of a medical examination, the costs of which are typically paid by the policyholder.
These waiting periods and their requirements must be clearly disclosed to applicants before policy purchase.
The bill prohibits pet insurers from requiring medical examinations for policy renewals and mandates compliance
with the Florida Insurance Code for additional benefits included in policies. Furthermore, it ensures that an
applicant's eligibility for pet insurance is not tied to participation in a wellness program. (Section 3).
Marketing and Sales of Wellness Programs
The bill prohibits pet insurers and their agents from misrepresenting wellness programs as pet insurance. It
mandates that if wellness programs are offered alongside pet insurance, they must be separate and not required
for pet insurance purchase. Additionally, the costs, terms, and products of wellness programs must be distinct from
pet insurance. Clear disclosures must be provided to applicants and policyholders regarding the nature of wellness
programs, and wellness benefits within pet insurance policies are recognized as insurance. (Section 3).
1 "Certain conditions" referenced in this sentence include illnesses, diseases, or orthopedic conditions not resulting from an accident, as
specified within the context of the bill JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
3
Agent and Broker Training Requirements
The bill requires specific training for agents and brokers involved in selling pet insurance policies. Agents and
brokers must obtain appropriate licensing and complete specified training before engaging in the sale, solicitation,
or negotiation of pet insurance policies. Pet insurers are responsible for ensuring that their agents and brokers
receive training on preexisting conditions, waiting periods, and the distinctions between pet insurance and
wellness programs. Additionally, training must cover chronic conditions, congenital anomalies, hereditary
disorders, and administrative aspects of pet insurance policies. Satisfaction of training requirements from other
states with substantially similar provisions is recognized as meeting the training standards in the state. (Section 3).
Enforcement, Applicability, and Rulemaking Authority
A violation of the bill’s requirements will be a violation of the Florida Insurance Code. Additionally, it clarifies that
while all other relevant insurance laws apply to pet insurance, the specific regulations outlined in this bill take
precedence over any conflicting general provisions. The bill does not restrict the types of exclusions pet insurers
can employ in their policies nor does it mandate the inclusion of any specific limitations or exclusions.
Furthermore, the bill grants the commission the authority to adopt rules and regulations essential for the effective
administration of this section. (Section 3).
The bill provides an effective date of January 1, 2026. (Section 4).
RULEMAKING:
Sufficient rulemaking authority for the FSC and OIR to administer the bill’s provisions is provided.
Lawmaking is a legislative power; however, the Legislature may delegate a portion of such power to executive
branch agencies to create rules that have the force of law. To exercise this delegated power, an agency must
have a grant of rulemaking authority and a law to implement.
FISCAL OR ECONOMIC IMPACT:
STATE GOVERNMENT:
The bill necessitates the incorporation of pet insurance into the information technology systems of OIR, resulting in
a one-time impact. However, OIR existing resources have the capacity to absorb this impact.
2
PRIVATE SECTOR:
The bill may positively impact the private sector if the regulatory efficiency it establishes results in lower
production costs for pet insurance providers.
RELEVANT INFORMATION
SUBJECT OVERVIEW:
National Association of Insurance Commissioners
The National Association of Insurance Commissioners (NAIC) serves as the insurance standard-setting and
regulatory support body in the United States.
3 Comprised of insurance regulators from all 50 states, the District of
2
Email from Kevin James, Deputy Legislative Affairs Director, Department of Management Services, HB 1465 Bill Analysis (Jan. 25, 2024).
The bill analysis has not yet been received; however, DMS provided similar information in its analysis of last year’s legislation, and this
section of the bill remains identical to last year’s version. JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
4
Columbia, and five U.S. territories, the NAIC aids state regulators in fulfilling their public service mandate.
4 It
achieves this by setting standards and regulatory best practices, facilitating the exchange of information, offering
regulatory support services, and educating consumers, industry professionals, and government stakeholders on
the state-based insurance regulatory framework of the United States.
5
Office of Insurance Regulation
The Office of Insurance Regulation (OIR) regulates specified insurance products, insurers, and other risk bearing
entities in Florida.
6 The Financial Services Commission (FSC), composed of the Governor, the Attorney General, the
Chief Financial Officer, and the Commissioner of Agriculture, serves as agency head of the OIR for purposes of
rulemaking. Further, the FSC appoints the OIR commissioner.
As part of their regulatory oversight, the OIR may suspend or revoke an insurer’s certificate of authority under
certain conditions.
7 The OIR is responsible for examining the affairs, transactions, accounts, records, and assets of
each insurer that holds a certificate of authority to transact insurance business in Florida.
8 As part of the
examination process, all persons being examined must make available to the OIR the accounts, records, documents,
files, information, assets, and matters in their possession or control that relate to the subject of the examination.
9
The OIR is also authorized to conduct market conduct examinations to determine compliance with applicable
provisions of the Insurance Code.
10
Current Situation - Pet Insurance
Pet insurance offers coverage for accidents and illnesses primarily for household pets, notably dogs and cats.
11
While classified and regulated as Property and Casualty (P/C) insurance
12, it parallels human health insurance in
providing annual coverage subject to predetermined rates and conditions.
13 Originating in the U.S. in 1980, pet
insurance has experienced significant expansion since its inception.
14
The North American Pet Health Insurance Association (NAPHIA) serves as the leading advocacy group,
representing over 99 percent of the U.S. and Canada pet health insurance industry.
15 Notably, in 2017, NAPHIA
members witnessed growth, with total premium volume reaching approximately $1.03 billion in the U.S., marking
a substantial 23.2 percent increase from the previous year.
16 In the U.S. and its territories, direct written premiums
amounted to roughly $640 billion.
17 Despite the rapid growth, pet insurance still represents a small percentage of
the total P/C market.
18
Pet insurance policies typically cover various veterinary expenses, including
19:
Accidents: coverage for injuries resulting from accidents, such as broken bones or ingesting foreign objects.
3 NAIC, Our Story, https://content.naic.org/about (last visited Feb. 28, 2025).
4 Id.
5 Id.
6 S. 20.121(3)(a), F.S.
7 S. 624.418, F.S.
8 S. 624.316(1)(a), F.S.
9 S. 624.318(2), F.S.
10 The Code is comprised of chs. 624-632, 634-636, 641, 642, 648, and 651, F.S. See S. 624.3161, F.S.
11 National Association of Insurance Commissioners, A Regulator’s Guide to Pet Insurance, p. 3 https://content.naic.org/sites/default/files
(last visited Feb. 28, 2025).
12 Casualty insurance is a broad category of insurance coverage for individuals, employers, and businesses against loss of property, damage,
or other liabilities. Casualty insurance includes vehicle insurance, liability insurance, and theft insurance. Liability losses are losses that
occur as a result of the insured’s interactions with others or their property. See Investopedia, Casualty Insurance: Definition, Types, and
Examples, https://www.investopedia.com/terms/c/casualtyinsurance.asp (last visited Feb. 28, 2025).
13 Id.
14 Id.
15 Id.
16 Id at 4.
17 Id.
18 Id.
19 Forbes, What Does Pet Insurance Cover?, https://www.forbes.com/advisor/pet-insurance/what-does-pet-insurance-cover/ (last visited
March 3, 2025). JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
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Illnesses: coverage for treatments related to illnesses such as cancer, diabetes, or infections.
Routine Care: some policies offer optional coverage for routine care, including vaccinations, wellness
exams, and dental cleanings.
Hereditary and Congenital Conditions: certain policies may cover hereditary and congenital conditions,
although these often have specific limitations and waiting periods.
In 2017, a survey by the American Pet Products Association revealed that approximately 68 percent of U.S.
households, totaling around 84.65 million families, had at least one pet, including dogs, cats, or other animals.
20 Of
these households, about 60 million owned at least one dog, and 47 million had at least one cat.
21 Despite this large
number of pet owners, there's considerable room for growth in the pet insurance sector.
22 However, only about 1.5
million dogs and 300,000 cats were insured in 2017, representing less than 2 percent of dogs and less than 0.5
percent of cats owned in the country.
23 In the U.S., there are roughly 90 million household dogs and 95 million
household cats, indicating a substantial potential market for pet insurance coverage.
24
Pet insurance coverage in the U.S. has seen consistent annual growth rates of 15 percent to 20 percent over the
past five years.
25 The distribution of pet insurance is notably concentrated in larger urban areas, with California
and New York emerging as the primary markets.
26 For a visual representation of the distribution of pets and Gross
Written Premiums (GWP) by state, please refer to the chart below.
27 According to data from NAPHIA members, the
total premium volume in the U.S. reached approximately $3.9 billion by the end of 2023, with a slight slowdown in
growth observed in 2023.
28
As companion animals live longer, veterinary care costs are rising, prompting more pet owners to consider
insurance for managing expenses related to preventive care, illnesses, and emergencies. In 2023, the North
20 National Association of Insurance Commissioners, A Regulator’s Guide to Pet Insurance, p. 4
https://content.naic.org/sites/default/files/publication-pin-op-pet-insurance.pdf (last visited Feb. 28, 2025).
21 Id.
22 Id.
23 Id.
24 Id.
25 Id. at 7.
26 Id.
27 NAPHIA, State of the Industry Report 2023 Highlights, p. 24, NAPHIA-SOI2024-Report-Highlights_Public-May16.pdf (last visited Feb. 28,
2025).
28 Id. at 10. JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
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American pet insurance industry surpassed $4 billion in premiums, with over 6.25 million pets insured—a 20.9%
increase from 2022.
29 Data from NAPHIA indicates the average annual premium for pet insurance varies based on
the type of plan.
30 In 2023, for dogs, Accident & Illness plans averaged $675.61, while Embedded Wellness plans
cost $1,263.39.
31 For cats, the costs were $383.30 for Accident & Illness plans and $625.99 for Embedded Wellness.
Accident Only policies remain the most affordable, averaging $204.16 for dogs and $116.11 for cats.
32
Development of Regulatory Standards for the Pet Insurance Industry
In April 2019, the Pet Insurance Working Group was tasked with reviewing NAIC’s "A Regulator's Guide to Pet
Insurance" to determine if a model law or guideline was necessary to establish appropriate regulatory standards
for the pet insurance industry.
33 Subsequently, a request for Model Law development related to pet insurance was
adopted during the NAIC 2019 Spring National Meeting, addressing various aspects such as definitions,
disclosures, violations, producer licensing, preexisting conditions, reimbursement benefits, and regulations.
34
During the NAIC's Summer 2022 National Meeting in members voted to adopt the Pet Insurance Model Act, which
includes key provisions concerning pet wellness programs, preexisting conditions, consumer protections, and
training for insurance producers.
35 Currently, California, Delaware, Louisiana, Maine, Maryland, Nebraska, New
Hampshire, the Northern Mariana Islands, Vermont, and Washington have adopted a substantially similar version
of the NAIC model.
36
Current Situation – Florida
Currently, several companies offer pet insurance in Florida; however, Florida law does not separately regulate pet
insurance. Below are companies that provide pet insurance:
37
Companies
Average Monthly
Cost
Waiting Periods
Maximum Annual
Limits
Pets Best
$54 for dogs
$22 for cats
14 days for
illnesses
Two days for
injuries
Six months for
orthopedic
conditions
$5,000 - Unlimited
Spot Pet
Insurance
$73 for dogs
$36 for cats
14 days for
illnesses
14 days for
injuries
$2,500 - Unlimited
Embrace
$52 for dogs
$37 for cats
48 hours for
accidents
14 days for
illnesses
Six months for
orthopedic
$5,000 - $30,000
29 NAPHIA, North American Pet Health Insurance Industry Continued Exceptional Growth Rate In 2023, https://naphia.org/news/soi-
report-2024/ (Last visited Feb. 28, 2024).
30 Id. at 20.
31 Id.
32 Id.
33 NAIC, Pet Insurance, https://content.naic.org/cipr-topics/pet-insurance (last visited March 3, 2025).
34 Id.
35 Id.
36 NAIC, Pet Insurance Model Act, https://content.naic.org/sites/default/files/model-law-state-page-633_0.pdf (last visited March 3, 2025).
37 Market Watch, The Best Pet Insurance Companies in Florida (2024), https://www.marketwatch.com/guides/pet-insurance/pet-insurance-
florida/ (last visited March 3, 2025).
JUMP TO SUMMARY ANALYSIS RELEVANT INFORMATION BILL HISTORY
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conditions
ASPCA Pet
Health
Insurance
$54 for dogs
$24 for cats
14 days for
illnesses
14 days for
accidents
$3,000 - $10,000
RECENT LEGISLATION:
YEAR BILL # HOUSE SPONSOR(S) SENATE SPONSOR OTHER INFORMATION
2024 CS/CS/HB 1465 Tuck DiCeglie The bill died in the Senate
Fiscal Policy Committee.
OTHER RESOURCES:
Pet Insurance Model Act
BILL HISTORY
COMMITTEE REFERENCE ACTION DATE
STAFF
DIRECTOR/
POLICY CHIEF
ANALYSIS
PREPARED BY
Insurance & Banking
Subcommittee
17 Y, 0 N Lloyd Herrera
Commerce Committee