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 Florida Office of Insurance Regulation (“Florida OIR”) recently took regulatory action against a New York-based company (“Company”) regarding its alleged unlicensed activities in Florida. According to the Florida OIR, the...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 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 U.S. Department of Labor (“DOL”) recently filed a lawsuit against UMR, Inc., a third-party administrator and UnitedHealth Group, Inc. subsidiary. The lawsuit alleges that UMR denied thousands of claims based on diagnosis...more
11/21/2023
/ Affordable Care Act ,
Claim Procedures ,
Denial of Insurance Coverage ,
Department of Labor (DOL) ,
Drug Testing ,
Employee Retirement Income Security Act (ERISA) ,
Enforcement Actions ,
Explanation of Benefits (EOBs) ,
Statutory Violations ,
TPAs ,
UnitedHealth
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
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
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
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
The New York Department of Financial Services (“NYDFS”) recently announced it has entered into a Consent Order with an insurance agency for alleged violations of New York’s Cybersecurity Regulation (the “NY Cybersecurity...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
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
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
We have previously reported on the new law that became effective this past summer in Washington requiring TPAs that administer self-funded workers compensation to become licensed with the Washington Department of Labor....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
The New York Department of Financial Services (“NYDFS”) recently announced that it has entered into a Consent Order with two affiliated life insurers for alleged violations of New York’s Cybersecurity Regulation (the “NY...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
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
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