Switching Company Health Insurance: What Does an Employer Need to Declare?

Changing the insurer for a company health scheme is more than comparing monthly premiums. The employer also needs to understand how existing medical conditions, ongoing treatment and the new policy's benefits will be handled. This guide explains the paperwork and practical checks without suggesting that a company director or HR manager should become the keeper of everyone's medical records.

What is a company health insurance switch declaration?

A switch declaration is information a receiving insurer asks for when assessing a group moving from another health insurance provider. It may ask whether the authorised company contact is aware of specified recent diagnoses, consultations or treatments among people to be insured. It is not the same as an individual employee's medical questionnaire, and not every switch needs one.

For example, Bupa announced on 10 March 2026 that its SME Group Medical Declaration Form is no longer required for groups of 50 or more employees switching to Bupa; groups of 20–49 answer a shorter set of questions, while groups below 20 continue to answer the existing questions. These are Bupa's stated rules, not a universal market threshold.

What does the authorised company contact actually confirm?

VitalityHealth's October 2026 guide, Understand the Switch Declaration — A guide for company contacts, says its authorised company contact confirms whether applicants meet the medical criteria in the relevant declaration to the best of the contact's knowledge. Vitality explicitly says the contact is not expected to know every employee's medical history, investigate employees' health, access medical records or diagnoses, confirm information never disclosed to them, or know what they could not reasonably be expected to know.

That is a helpful distinction: a company contact should answer accurately using information they reasonably have in their authorised role, rather than guess. If they know something relevant, they should not ignore it; if unsure how the question applies, they should ask the adviser or insurer before signing. The wording of the actual form controls what must be declared.

Important Vitality exception: its October 2026 document states that business healthcare schemes with 100 or more employees applying for either CPME or MHD underwriting have no switch declaration to sign. This is a Vitality-specific statement for those circumstances. It does not mean every insurer waives declarations at 100 employees, or that all Vitality schemes avoid other application requirements.

Does an employer need to ask employees about private medical conditions?

Not simply because a switch is being considered. Under the Vitality process described above, the contact is specifically not expected to investigate employees' health. However, employers must follow the receiving insurer's actual instructions; some schemes or underwriting options may require employees to provide information directly to the insurer.

Employee medical information is particularly sensitive. The Information Commissioner's Office (ICO) explains that workers' health data is special category personal data, requiring a lawful basis and an additional special-category condition before processing. Its employment records guidance also says employers should share no more information with a health scheme provider than is needed and restrict access to those who need it.

In practice, do not circulate a spreadsheet asking colleagues to disclose diagnoses just to complete a company-contact declaration. Check the insurer's process and arrange for any necessary individual disclosures to be handled appropriately and securely. The legal basis and handling arrangements must be assessed for the actual situation.

What do CPME and MHD mean?

CPME: continued personal medical exclusions

CPME is terminology used in some company health insurance switching arrangements for carrying forward the individual underwriting position from an existing policy, including medical exclusions where applicable. Other insurers may use terms such as continuing medical exclusions (CME) or no further underwriting. The labels and eligibility criteria are not necessarily interchangeable.

AXA Health explains that under its continuing medical exclusions option, previous underwriting arrangements may continue when a business switches, but the new AXA plan's rules and benefits still apply. Bupa's No Further Underwriting guide similarly says previous exclusions can carry forward and further information or exclusions may be relevant. Neither statement guarantees identical cover after a move.

MHD: medical history disregarded

Medical history disregarded generally means the insurer agrees not to impose medical underwriting exclusions based on conditions that existed before joining, but only within the new policy's terms, limits and general exclusions. It does not make every treatment claimable. For example, a plan might still restrict chronic-condition management or limit particular outpatient benefits.

AXA Health says its small-business MHD option is available when looking to cover 15 employees or more, and that it does not ask the employer or employees for medical history declarations under that option. This is AXA's stated product eligibility, not a rule for Vitality, Bupa or Aviva.

How do insurer requirements differ?

VitalityHealth: the October 2026 company-contact guide defines the reasonable-knowledge approach and its 100+ employee CPME/MHD no-declaration exception. The relevant switch form and current quotation still need checking.

Bupa: its March 2026 intermediary update uses a different group-size approach: no SME medical declaration at 50+ employees, shorter questions for 20–49 and the existing questions for fewer than 20. Bupa also has distinct underwriting and eligibility rules for different products.

AXA Health: its business switching guidance says for groups of three or more it asks one medical-awareness question, to the best of the contact's knowledge, concerning certain recent cancer diagnoses/treatment and conditions likely to require inpatient admission. Groups of one or two require more medical-history details. AXA's separate MHD arrangements have different requirements.

Aviva and other insurers: do not assume any of the group-size thresholds or exact declaration questions above apply. Obtain the latest insurer-specific quotation, application, underwriting guide and scheme terms before advising a company to sign.

Does switching preserve cover for existing conditions?

Not automatically. A switch may be accepted on continuation terms, MHD terms or another basis, but the new insurer's benefit limits, hospital lists, exclusions and underwriting decision matter. A condition previously eligible for treatment might not receive identical benefits under a different plan.

Consider a fictional employee receiving physiotherapy for a recurring back problem. If their employer moves schemes on accepted continuation terms, the employee may retain an eligible underwriting position for that condition, but the new plan might allow fewer therapy sessions or use a different provider network. If the employer instead chooses fresh underwriting, the outcome could be different again. The receiving insurer should confirm how the specific scheme will treat ongoing claims and existing conditions before the old cover ends.

Our guide to pre-existing conditions explains the wider difference between underwriting methods. For employers, our business health insurance page explains the cover options.

Seven checks before signing or switching

1. Identify the exact underwriting basis. Ask whether the proposed scheme is CPME/CME, MHD or another arrangement, and who qualifies.
2. Read the actual declaration. Check its precise look-back periods, conditions, employee count rules and definition of what the contact knows.
3. Do not guess about employees. Ask the insurer or adviser about an ambiguous answer; do not investigate private medical histories without a proper basis.
4. Compare benefits as well as price. Check outpatient limits, therapies, mental health, cancer benefits, hospital networks, excesses and general exclusions.
5. Check existing treatment and claims. Ask how authorised treatment, planned procedures and ongoing claims will be handled on the new policy.
6. Check the dates. Coordinate the new start date and old scheme end date to avoid an unintended gap, and confirm any cancellation conditions.
7. Keep a record. Retain the agreed insurer answers, scheme documentation and confirmation of underwriting terms without collecting unnecessary employee medical data.

Frequently asked questions

Can I sign if I do not know every employee's medical history?

Vitality's October 2026 guidance says yes, its contact answers on the basis of what they reasonably know; they are not expected to investigate everyone's health. Read the actual declaration and seek clarification if you are aware of something potentially relevant. Other insurers may use different forms and rules.

Does a switch declaration mean the insurer can see employees' medical records?

No. A company-contact declaration is not itself a general authorisation for an employer to access medical records. Any separate requests for medical information must be handled under the insurer's process and applicable privacy requirements.

Is medical history disregarded unlimited cover?

No. MHD addresses pre-existing-condition underwriting exclusions; it does not remove the policy's benefit limits, general exclusions or treatment eligibility rules.

Should a company cancel its existing scheme as soon as the new quote is cheaper?

No. Confirm the new insurer's acceptance, start date, underwriting terms and treatment arrangements first. A cheaper premium alone does not establish equivalent protection.

How Bright Cover can help

Bright Cover can compare group health insurance options and help the authorised company contact understand the proposed insurer's questions before a decision is made. See our business health insurance service, FAQs or request a no-obligation quote.

Important: This is general information, not legal advice, a guarantee of continuity or confirmation that a particular claim will be covered. The Vitality statements above are attributed to its October 2026 company-contact guide. Insurer forms, group-size thresholds, underwriting acceptance and policy benefits can change; always use the current documents and obtain written clarification where necessary.