The West Virginia Office of the Insurance Commissioner (“WV OIC”) recently took regulatory actions against four unaffiliated Pharmacy Benefit Managers (“PBMs”) that were operating in West Virginia without a PBM license. These...more
The U.S. Department of Labor (“DOL”) recently entered into a settlement agreement with a New York-based insurer and third-party administrator (“Company”) of employer group health plans governed by the Employee Retirement...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
On September 18, 2023, the Florida Office of Insurance Regulation (“OIR”) published proposed rules to implement provisions of the Prescription Drug Reform Act (Florida Senate Bill 1550) governing Pharmacy Benefit Managers...more
11/16/2023
/ Certificate of Authority ,
Florida ,
Health Insurance ,
Insurance Regulations ,
Licensing Rules ,
New Regulations ,
Pharmaceutical Industry ,
Pharmacies ,
Pharmacy Benefit Manager (PBM) ,
Prescription Drug Coverage ,
Prescription Drugs ,
Regulatory Reform
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
8/8/2023
/ Florida ,
Health Insurance ,
Healthcare ,
Insurance Claims ,
Insurance Regulations ,
Licensing Rules ,
Pharmaceutical Industry ,
Pharmacy Benefit Manager (PBM) ,
Prescription Drugs ,
Regulatory Reform ,
Regulatory Requirements ,
TPAs
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
New York recently enacted legislation, SB 3762, requiring Pharmacy Benefit Managers (“PBMs”) doing business in New York to register and then become licensed with the New York Department of Financial Services (“DFS”). The law...more
4/27/2022
/ Covenant of Good Faith and Fair Dealing ,
Health Insurance ,
Healthcare ,
Healthcare Reform ,
New Legislation ,
New York ,
Pharmaceutical Industry ,
Pharmacy Benefit Manager (PBM) ,
Prescription Drugs ,
Regulatory Requirements ,
TPAs
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
In the fall of 2019, we reported that Vermont enacted Senate Bill 41, which granted the Commissioner of the Vermont Department of Financial Regulation (the “Department”) jurisdiction over entities that administer one or more...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
The Oregon Department of Consumer and Business Services (“Oregon Department”) recently announced it had entered into an Order to Cease and Desist, Final Order Assessing Civil Penalty and Consent to Entry of Order (“Order”)...more
Polsinelli is pleased to share the June 2016 Third Party Administrator Newsletter. This newsletter covers topics throughout the year that impact TPAs. Information specific to Polsinelli's TPA practice is also included....more
7/11/2016
/ Filing Requirements ,
Health Insurance ,
Insurance Industry ,
Insurance Regulations ,
Licensing Rules ,
Medicaid ,
NAIC ,
Plan Administrators ,
Policies and Procedures ,
Prescription Drugs ,
Proposed Legislation ,
Registration Requirement ,
Service Agreements ,
Third-Party Agents
The Washington State Department of Health has promulgated a new rule clarifying the Department's authority to issue civil penalties against health carriers and third-party administrators. This rule, which is outside the...more
The Department of Labor Employee Benefits Security Administration issued guidance on the issuance of fixed indemnity insurance on January 24, 2013 in its FAQs about Affordable Care Act Implementation Part XI. These FAQs are...more