Third Party Administrator (TPA) Licensing and Compliance Services
Steven L. Imber
Health Care Services
Insurance Business and Regulatory Law
Polsinelli’s Insurance Business and Regulatory group has significant experience representing third party administrators (TPAs) on a national basis regarding a variety of business and compliance issues. The group includes attorneys who were formerly in-house counsel for TPAs as well as attorneys who were formerly insurance regulators. Additionally, several of our attorneys are also members of the Federation of Regulatory Counsel.
Our experience in the third party administrator industry is demonstrated by these representative examples:
National and multi-state TPA licensing projects, including off-shore entities located in India and the Philippines seeking licensure as a TPA in the United States.
National and multi-state Pharmacy Benefit Manager (PBM), Adjuster and Insurance Producer licensing projects.
Multi-state Service Company licensing projects involving the administration of workers’ compensation coverage.
Maintaining licensure as a TPA, PBM, Adjuster, Insurance Producer, or Service Company through periodic renewal and annual report filing.
Assistance with ancillary state filing and registration requirements such as All-Payer Claims Databases and Vaccination Assessments.
Advised clients regarding business, regulatory and compliance matters associated with mergers, acquisitions, and divestures involving entities licensed as a TPA.
Multi-state research regarding the statutory exemptions to the TPA licensing and regulatory requirements.
National research regarding the reviews and on-site audits insurers are required to perform with respect to their TPA business partners.
Research and analysis regarding exemptions to the TPA licensing and regulatory requirements.
Assistance with questions and issues that arise under The Employee Retirement Income Security Act (ERISA), The Health Insurance Portability and Accountability Act (HIPAA), and The Patient Protection and Affordable Care Act (ACA).
Monitor regulatory and legislative activity affecting our TPA clients and provide periodic reports regarding such activity.
Negotiate and draft Administrative Services Agreements and subcontract, including assistance with statutorily-mandated provisions and business provisions.
Assistance in developing a TPA Regulatory Addendum designed to comply with the statutorily-mandated provisions applicable under the TPA laws on a national basis.
Assistance with inquiries and formal regulatory actions brought by state insurance departments and attorney general offices.
Attend industry meetings, including meetings held by the National Association of Insurance Commissioners (NAIC), National Conference of Insurance Legislators (NCOIL), Insurance Regulatory Examiners Society (IRES), Association of Insurance Compliance Professionals (AICP), and Securities & Insurance Licensing Association (SILA).
Polsinelli's Insurance Business and Regulatory group stays apprised of TPA industry trends and emerging TPA regulatory and compliance issues, publishes a newsletter and distributes eAlerts that are solely dedicated to the TPA industry. To subscribe to future TPA updates and eAlerts by email, please contact Steve Imber at
Virgin Islands Enacts New TPA Law
July 20, 2017
Kansas Strengthens Third Party Administrator Laws
New Indiana Insurance Department Bulletin Changes TPA Licensing and TPA Renewals
Pharmacy Benefit Managers Face New Licensing Requirements
Recent Regulatory Actions Against TPAs
Third Party Administrator Update: TPA Regulatory and Legislative Developments
July 8, 2016
TPA Agreement Filing and Compliance Requirements
May 26, 2016
California Division of Workers’ Compensation Takes Action Against TPAs and Will Increase Audits of TPAs in 2016
March 31, 2016
New Legislation To Register and Regulate TPAs Proposed in Washington State
March 11, 2016
Texas Department of Insurance Takes Action Against Companies For Utilization Review Non-Compliance
January 7, 2016
"'Practical' means you don't over lawyer and you are consistently delivering a better product at a lower cost. We get that at Polsinelli."
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