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Insurance2026-06-01 · 12 min read

NAIC Pet Insurance Model Act and State Regulations — What Pet Owners and Clinics Need to

Over fifteen states have adopted NAIC Pet Insurance Model Act rules. Coverage disclosures, pre-existing condition protections, free-look periods, and what changes for pet owners and veterinary.

Ran Chen
Ran Chen
Founder, VetMedGuide. Life-sciences operator and 10× global market-access lead.
Published

Pet insurance is regulated as property and casualty insurance in the United States, not as health insurance. There is no federal law that governs how pet insurance is marketed, sold, or administered. For years, that meant pet owners had to navigate a market with inconsistent disclosure standards, vague pre-existing condition definitions, and limited recourse when claims were denied.

The National Association of Insurance Commissioners (NAIC) Pet Insurance Model Act, adopted in 2022, is the first structured attempt to create a national framework for pet insurance consumer protection. As of 2026, more than fifteen states have adopted legislation based on or influenced by the model act, and more states are expected to follow.

This article explains what the model act covers, which states have adopted it, what changes for pet owners and veterinary clinics, and where the gaps remain.

Why the Model Act Was Needed

Before the model act, pet insurance regulation was a patchwork. California was the only state with a dedicated pet insurance law, passed in 2014 after a surge of consumer complaints about confusing and misleading policies. In most other states, pet insurance was treated the same as any other property and casualty product, with no specific rules about how insurers had to disclose exclusions, waiting periods, or pre-existing condition definitions.

The NAIC established a Pet Insurance Working Group in 2019 after publishing a white paper identifying these gaps. The working group held twenty-four meetings over two years with input from veterinarians, consumer representatives, and insurance industry members before voting to adopt the model act in July 2022.

What the Model Act Requires

The model act addresses four key areas: consumer protections, pre-existing condition standards, wellness program differentiation, and producer training requirements.

Consumer protections

Insurers in adopting states must:

  • Provide a free-look period — 15 days from receipt of the policy during which a policyholder can cancel a new policy for a full refund if the terms are not satisfactory, provided no claim has been filed.
  • Disclose waiting periods clearly before purchase. The model act prohibits waiting periods for accidents and limits illness and orthopedic waiting periods to no more than 30 days.
  • Disclose policy limits, deductibles, reimbursement levels, and exclusions in plain language before the policy is purchased.
  • Disclose whether and how claim history, pet age, or geographic location could affect future coverage or premiums.
  • Explain the insurer's basis for determining usual and customary fees and how that basis is applied in calculating claim payments.
  • Provide a clear and conspicuous link to the fee-determination methodology on the insurer's website.

Pre-existing condition standards

This is the most impactful change for pet owners. Under the model act:

  • Insurers may exclude coverage for pre-existing conditions — the model act does not ban pre-existing condition exclusions.
  • However, the burden of proof is on the insurer to demonstrate that the pre-existing condition exclusion applies to the specific condition for which a claim is being made.
  • A pre-existing condition is defined as one where, prior to the policy effective date or during a waiting period: a veterinarian provided medical advice, the pet received previous treatment, or — based on verifiable sources — the pet had signs or symptoms directly related to the condition.
  • A condition that is covered under a policy cannot be considered pre-existing on any renewal of that policy.
  • If a medical examination is required to activate coverage, the insurer must clearly disclose that the examination documentation may result in a pre-existing condition exclusion.

This shifts a significant practical burden. In states without these protections, a pet owner might face a denial letter asserting a pre-existing condition with little transparency about how that determination was made. In model-act states, the insurer has to provide the evidence.

Wellness program differentiation

Many pet insurance companies bundle or market wellness programs alongside insurance policies. The model act requires insurers and their producers to clearly differentiate pet wellness programs from pet insurance policies. A wellness program is defined as a separate product — or one offered in conjunction with insurance — that covers preventive care services such as vaccinations, dental cleanings, or flea prevention.

This distinction matters because wellness programs are not insurance. They do not have the same regulatory protections, and their value depends on how closely the covered services match what the pet owner would actually use. The model act requires that this difference be disclosed so consumers are not confused into thinking a wellness program provides the same financial protection as an accident-and-illness policy.

Producer training requirements

The model act requires insurance producers (agents and brokers) who sell pet insurance to complete training on:

  • Pre-existing condition definitions and how they apply to claims.
  • Waiting period structures and requirements.
  • The difference between pet insurance and wellness programs.
  • General pet insurance product knowledge.

This is a minimum training floor. The goal is to ensure that the person selling the policy understands the product well enough to explain it accurately to the consumer.

States That Have Adopted the Model Act

As of mid-2026, more than fifteen states have adopted pet insurance legislation based on or influenced by the NAIC model act, with several additional states advancing legislation in 2026. Key adopters include:

State Year adopted Notable details
California 2014 (expanded 2024) Original law predates model act; expanded to mirror model act guidance
Maine 2023 First state to adopt modified version; training requirements effective Jan 2023
New Hampshire 2023 Adopted with modifications (N.H. Rev. Stat. Ann. §§ 402-P:1 to 402-P:6)
Delaware 2023 Adopted model act-based legislation
Louisiana 2023 (effective 2024) Amended crop and livestock insurance regulations
Mississippi 2023 Adopted model act-based legislation
Nebraska 2023 Adopted model act-based legislation
Washington 2023 Adopted model act-based legislation
Maryland 2024 Adopted model act-based legislation
Pennsylvania 2024 Implemented NAIC-based legislation
Vermont 2024 Adopted model act-based legislation
Ohio 2025 Adopted model act-style legislation (Ohio Rev. Code §§ 3970.01 to 3970.08)
Florida 2025 (effective Jan 1, 2026) HB 655 adds pet insurance to property insurance definition; requires disclosures on claims payment, waiting periods, deductibles, exclusions, and medical exams
Hawaii 2025 Adopted model act-influenced legislation
Rhode Island 2025 Pet Insurance Act enacted
New Jersey 2025 Pet Insurance Act signed into law
Idaho Limited lines Separate limited lines authority for pet insurance (not model act adoption)
Virginia Limited lines Separate limited lines authority for pet insurance (not model act adoption)
Others Various Additional states are actively considering legislation in 2026, including Montana

The NAIC maintains a state adoption tracker on its website, and the list is expected to grow as more state legislatures take up pet insurance bills.

What Changes for Pet Owners

If you live in a state that has adopted model act legislation:

  • You get a free-look period. You can purchase a policy, review the full terms, and cancel within 15 days for a full refund if the coverage is not what you expected, provided no claim has been filed.
  • Pre-existing condition denials must be proven by the insurer. The insurer cannot simply assert that a condition is pre-existing. It must show that veterinary records, treatment history, or documented signs and symptoms support the exclusion.
  • Waiting periods are capped. Insurers cannot impose waiting periods for accidents. Illness and orthopedic waiting periods are limited to 30 days.
  • Wellness programs must be identified as separate from insurance. You will receive explicit disclosure about what is insurance and what is a wellness add-on.

If you live in a state that has not adopted the model act, these protections do not automatically apply. You should read policy documents carefully, ask specific questions about pre-existing condition definitions and waiting periods before purchasing, and compare how different insurers handle claim documentation.

What Changes for Veterinary Clinics

Veterinary clinics are not directly regulated by the model act — it governs insurers and their producers. But the model act creates indirect effects that clinics should understand:

Medical records and claim documentation

Because the model act shifts the burden of proof for pre-existing conditions to the insurer, insurers in adopting states may request more detailed veterinary records to support or deny claims. Clinics should ensure their medical records are:

  • Complete, legible, and dated.
  • Objective in documenting clinical findings — describing what was observed rather than speculating about when a condition may have started.
  • Available in a format that can be shared with the pet owner promptly when requested for a claim submission or appeal.

Ambiguous or incomplete records can complicate a pet owner's claim. A thorough medical record protects both the client and the practice.

The wellness-versus-insurance conversation

Because the model act requires clear differentiation between wellness programs and insurance, clinic staff who discuss financial planning with clients should understand the distinction:

  • Pet insurance covers unexpected accidents and illnesses. It reimburses a percentage of eligible veterinary costs after the deductible is met.
  • Wellness programs cover expected preventive care — vaccinations, dental cleanings, parasite screening. They are essentially a prepaid plan for routine services.

Clients who purchase a wellness program thinking it is insurance may be surprised when a major illness or emergency is not covered. Clinics that proactively explain the difference help clients make better financial decisions.

Staff training on insurance basics

While the model act's training requirements apply to insurance producers, not veterinary staff, clinics benefit from having team members who can:

  • Explain the difference between accident-and-illness coverage and wellness add-ons.
  • Help clients understand what pre-existing conditions mean for their specific pet.
  • Provide clear, objective medical records that support accurate claim adjudication.
  • Avoid giving financial or insurance advice while still being a knowledgeable resource.

Where the Gaps Remain

The model act is a significant step forward, but it does not solve every problem:

  • Most states have not adopted it. As of 2026, more than fifteen states have adopted model act-based or influenced legislation, but the majority of states still rely on general property and casualty insurance rules, which provide no pet-specific consumer protections.
  • Pre-existing condition exclusions are still permitted. The model act requires the insurer to prove the exclusion applies, but it does not ban pre-existing condition exclusions. Pets with documented health issues before enrollment may still face limited or no coverage for those conditions.
  • The model act does not standardize reimbursement levels or benefit schedules. Two policies that both advertise "80 percent reimbursement" may calculate that percentage differently — one based on the actual invoice and another based on a usual-and-customary fee schedule. The model act requires disclosure of the methodology, but it does not mandate a single approach.
  • Curable versus incurable pre-existing conditions are not uniformly defined. Some insurers distinguish between conditions that have been resolved (curable) and those that are ongoing (incurable), offering coverage for the former after a symptom-free period. The model act does not require this distinction or set a standard for what counts as cured.

How to Use This Information

For pet owners:

  • Check whether your state has adopted model act legislation. If it has, you have specific disclosure and protection rights.
  • Use the free-look period to read the full policy before committing.
  • When comparing policies, ask specifically how pre-existing conditions are defined and proven, what the waiting periods are for accidents versus illnesses versus orthopedic conditions, and how the reimbursement amount is calculated.
  • Do not assume that a wellness program provides the same coverage as an insurance policy.

For veterinary clinics:

  • Understand which of your patients are insured and which insurers operate under model act rules in your state.
  • Maintain thorough, objective medical records — they are the primary evidence in pre-existing condition disputes.
  • Train client-facing staff on the difference between insurance and wellness programs so they can guide conversations accurately without giving financial advice.
  • If your practice recommends specific insurers or helps clients with claim paperwork, know the disclosure requirements that apply in your state.

Sources

Topics
Pet Insurance & Claims
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