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Third Party Administrators Regulatory Requirements

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Recent Regulatory Actions Against TPAs in South Dakota

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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

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Third Party Administrator & Pharmacy Benefit Manager 2023 Newsletter: TPA & PBM Licensing And Compliance Developments

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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

Akerman LLP - Health Law Rx

New Florida Law Will Impose A Third-Party Administrator Licensing Requirement for Pharmacy Benefit Managers

On May 3, 2023, the Florida governor signed a comprehensive law (SB 1550) regarding pharmacy benefit managers (PBMs). This new law imposes significant new requirements on PBMs. This article discusses only one of these new...more

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Louisiana Insurance Department Revises and Reissues Bulletin 07-01 Regarding Catastrophe Response Plans

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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

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New York Enacts Legislation Regulating Pharmacy Benefit Managers

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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

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Pharmacy Benefit Managers Licensing and Compliance Developments

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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

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Third Party Administrator Newsletter - December 2021

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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

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Multistate Regulatory Action a Significant Reminder that Insurers Must Only Conduct Business with Licensed TPAs

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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

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New TPA Law Governing Workers Compensation in Washington State

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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

Nossaman LLP

New Disclosure Requirements for Those that Contract with ERISA Group Health Plans

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Included within the 5539 pages of statutory changes in the Consolidated Appropriations Act, 2021 (the COVID-19 relief bill signed into law at the end of December 2020) are important new “transparency” laws that affect third...more

Morgan Lewis - ML Benefits

Mental Health Parity Transparence: Consolidated Appropriations Act, 2021

As we addressed in our recent LawFlash covering the Consolidated Appropriations Act, 2021 (Act), the Act includes several requirements to enhance group health plan transparency. One provision we wanted to further highlight...more

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Third Party Administrator Licensing and Compliance Services: Multistate Regulatory Action a Significant Reminder that Insurers...

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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

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Recent Regulatory Actions Against TPAs (UPDATED)

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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

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Third Party Administrator (TPA) Licensing and Compliance Developments - January 2020

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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

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Third Party Administrator Newsletter - December 2019

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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

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Third Party Administrator (TPA) Licensing and Compliance Developments - November 2019

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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

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Hawaii Legislature Passes New TPA Law

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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 of only a handful of states that do not...more

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Nevada to Strictly Enforce TPA Financial Statement Due Date

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The Nevada Division of Insurance (“Division”) recently issued Bulletin 18-006 to provide guidance to TPAs regarding the due date for filing their annual reports with the Division pursuant to NRS 683A.08528....more

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Kansas Regulatory Action: A Reminder That Insurers Must Maintain Oversight of Third Party Administrators

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The Kansas Insurance Department (“Department”) recently took regulatory action against an insurer which allegedly violated Kansas insurance laws. Specifically, the Department initiated a Market Conduct inquiry of accident and...more

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