Are Changes In Premium and Benefits Considered a New Policy or Continuation of a Previous One ?
In Bronstein v. Ina Life Insurance Co. of North America, 207 Ill. App. 3d 910, 913, 566 N.E.2d 484, 152 Ill. Dec. 797 (1990), the court held that a new effective date, new premium, and new benefit level were changes sufficiently material to result in a new policy rather than a continuation of the previous policy.
Commenting that the new policy indisputably "required the offer and acceptance" of several new terms, the court held that the new terms represented "material and substantial differences" between the policies, with the result that the second policy could not be considered a continuation of the first. Bronstein, 207 Ill. App. 3d at 913;
See also Doe v. Illinois State Medical Inter-Insurance Exchange, 234 Ill. App. 3d 129, 137-38, 599 N.E.2d 983, 174 Ill. Dec. 899 (1992) (differences in effective dates, premiums, and requirement of regularly updated information such as current professional standing were "material and significant" such that the later policy was not a continuation of the previous policy).