To embed, copy and paste the code into your website or blog: On March 10, 2021, the New York State Department of Financial Services (“DFS”) issued Insurance Circular Letter No. 4 (“Circular Letter”),[1] which both explains modifications to the Insurance Law and the Public Health Law brought about by statutory changes in 2021 and sets forth two policy statements by DFS. More specifically, the Circular Letter summarizes a host of important statutory changes relating to common managed care issues, including administrative denials, utilization review, coding, and denials of pre-authorized services. In addition to covering statutory changes, the Circular Letter clarifies the DFS’s positions on when down-coding requires a utilization review determination and on the subsequent denial of a claim that had received pre-authorization. These changes relate to commercial and Medicaid products in New York; they do