The Portuguese Insurance and Pension Funds Supervisory Authority (ASF) published a list of insurance companies that have fully adopted, or intend to fully adopt, its recommendations on differentiating health insurance from “health plans”. The recommendations form part of ASF’s measures to strengthen regulation of the Sickness line and are intended to help consumers make informed choices by ensuring clearer product positioning. For insurers offering health insurance in Portugal, the recommended practices include avoiding the term “plan” to label coverage packages in health insurance products and using alternatives such as “option”; refraining from marketing “health plan” type products without risk coverage, subject to limited carve-outs related to negotiated provider pricing once coverage limits are exhausted and to ancillary access to discounted care where at least one risk coverage with medical expense reimbursement exists; revising pre-contractual information and policy wording to make clear that the product is health insurance, to be done at contract renewal or when a duplicate policy is requested; and running digital-channel information campaigns explaining the distinction, including that insurance-specific consumer redress mechanisms apply exclusively to health insurance. ASF also expects insurers to take steps to ensure their distribution channels respect the recommendations, which are non-binding but reflect ASF’s view of practices that best promote clarity, loyalty and transparency.

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