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One commenter said that small-expression, constrained-length insurance policies issuers must be permitted to promote a policy with a duration of less than twelve months, with a separate confirmed renewability rider, enabling the shopper to get a new policy devoid of underwriting. However, the Departments conclude that the 36-thirty day period utmost protection interval is a sensible and appropriate benchmark for interpreting the expression "limited-duration." By allowing COBRA coverage to last up to 36 months in some situation, Congress identified that 36 months qualifies as a temporary period of time of transition, for the duration of which protection of constrained length may be handy. The Departments are also substantially minimal in their capacity to choose an enforcement motion below the PHS Act current market regulations with respect to these kinds of transactions involving merchandise or instruments that are not well being insurance coverage protection. The Departments also imagine permitting renewal or extension of a brief-expression, confined-period insurance policies policy, but only to the extent the highest period of protection beneath a coverage is no lengthier than 36 months, serves to further distinguish this sort of quick-term, constrained-duration insurance from particular person health insurance coverage protection, which will have to be guaranteed renewable indefinitely, other than beneath certain confined circumstances. However, the name Joseon was even now commonly employed by Koreans to refer to their nation, even though it was no more time the official identify