The No Surprises Act: A Cost Saving Opportunity for Employer Plan Sponsors
Key Takeaways: A Florida-based Health Maintenance Organization (HMO) was fined for contracting with a Third Party Administrator (TPA) that was not licensed in Florida, violating its statutory obligation to ensure...more
Key Takeaways - The Delaware Department of Insurance (Department) is conducting targeted market conduct exams of Third Party Administrators (TPAs) for compliance with state insurance laws and regulations....more
The South Dakota Division of Insurance (“Division”) recently took regulatory action against a Texas-based Third Party Administrator (“TPA”) regarding its activities in South Dakota. According to the Division, the TPA...more
The Louisiana Insurance Department (“Department”) recently fined Express Scripts Administrators, LLC (“ESA”) $275,000 and MedImpact Healthcare Systems, Inc. (“MedImpact”) $250,000 for allegedly failing to pay electronically...more
Pharmacy Benefit Managers (PBMs) take note! Under Florida’s new Prescription Drug Reform Act, PBMs must be licensed as an insurance administrator (also known as a third-party administrator, or TPA). Under this new law, any...more
The Louisiana Insurance Department (“Department”) recently sent e-mail notifications to numerous third party administrators (“TPA”) regarding the failure to file their Catastrophe Response Plans with the Department by June 1,...more
Florida OIR Issues Informational Memorandum OIR-23-04M to PBMs - On July 19, 2023, the Florida Office of Insurance Regulation (“OIR”) issued Informational Memorandum OIR-23-04M (“Memorandum”) to Pharmacy Benefit Managers...more
South Dakota - The South Dakota Division of Insurance (“Division”) recently took regulatory action against a TPA that has held a valid TPA registration in South Dakota since 2006. In 2021, the TPA submitted its TPA...more
The Louisiana Insurance Department (“Department”) recently issued separate Cease and Desist Orders to both a TPA operating as a Pharmacy Benefit Manager (“PBM”) and the Office of Group Benefits, a Louisiana state agency that...more
The Louisiana Insurance Department (“Department”) recently revised and reissued Bulletin 07-01 to make all insurers, Health Maintenance Organizations (“HMO’s”) and Third Party Administrators (“TPA”) and provided updated...more
A third party administer administrator (“TPA”) based out of California recently entered into a Consent Order with the Texas Insurance Department (“Department”). The Consent Order focused on the fact that the TPA had acted...more
In response to calls for greater transparency in the prescription drug industry, 2021 continued a nationwide trend of increased state licensing and regulation of Pharmacy Benefit Managers (“PBMs”). In the last year, laws...more
New Law Regulating Health Care Benefit Managers in Washington State - We have previously reported on the new law that became effective this past summer in Washington requiring TPAs that administer self-funded workers’...more
A life and health insurer recently reached a settlement agreement with thirty-nine (39) state insurance departments following a targeted multistate market conduct examination (“Multistate Examination”). The Multistate...more
Washington has recently adopted legislation (Substitute House Bill 2409 that established Revised Code of Washington 51.14.179) that will impose new licensing and other regulatory requirements on workers compensation Third...more
A Regulatory Settlement Agreement was recently entered into by forty-one (41) states and an insurer as a result of a multistate targeted market conduct examination (“Multistate Examination”) of the insurer. The Multistate...more
The North Carolina Insurance Department (“Department”) recently announced a regulatory action against an insurer for alleged claims practices violations and contracting with a TPA before it became licensed in North Carolina....more
NEW JERSEY - The New Jersey Department of Banking and Insurance (“New Jersey Department”) recently took regulatory action against a TPA for untimely filing its annual report with the New Jersey Department....more
The Kansas Insurance Department (“Kansas Department”) recently issued a Summary Order against a Missouri-domiciled third party administrator (“Company”) revoking the Company’s Kansas non-resident TPA license....more
In response to calls for greater transparency in the prescription drug industry, 2019 continued a nationwide trend of increased state licensing and regulation of pharmacy benefit managers (“PBMs”). In the last year, laws...more
Vermont Regulatory Action: A Reminder that Insurers Must Maintain Oversight of Their TPA and PBM Business Partners The Vermont Department of Financial Regulation (the “Department”) recently took significant enforcement...more
The Vermont Department of Financial Regulation (the “Department”) recently took significant enforcement action against an insurer after determining that the insurer had violated various provisions of Vermont’s insurance laws,...more
Hawaii Insurance Department Establishes TPA Application Requirements - Recently enacted Hawaii Senate Bill (SB) 1212 imposes extensive licensing and regulatory requirements on third party administrators (TPAs) operating in...more
The Texas Insurance Department (TDI) recently issued Commissioners’ Bulletin No. B-0007-19 (the “Bulletin”) to Third Party Administrators (“TPAs”) and agents licensed in Texas. Specifically, the Bulletin is a reminder to TPAs...more
Hawaii Legislature Passes New TPA Law - Hawaii is expected to adopt legislation in the coming weeks that will impose licensing and other regulatory requirements on third party administrators (TPAs). Currently, Hawaii is one...more