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 multistate TPA licensing projects, including off-shore entities located in India and the Philippines seeking licensure as a TPA in the United States.
  • Assist clients with business, regulatory and compliance matters associated with mergers, acquisitions, and divestures involving entities licensed as a TPA.
  • Multistate research regarding the statutory exemptions to the TPA licensing and regulatory requirements.
  • 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.
  • National and multistate Pharmacy Benefit Manager (PBM), Adjuster and Insurance Producer licensing projects. 
  • Multistate Service Company licensing projects involving the administration of workers’ compensation coverage.
  • Assist clients with TPA, PBM, Adjuster, Insurance Producer or Service Company renewals and annual report filings.
  • Assistance with ancillary state filing and registration requirements such as All-Payer Claims Databases and Vaccination Assessments.
  • 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.
  • 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, please email TPA@polsinelli.com.

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Louisiana Insurance Department Issues Bulletin Emphasizing TPA Due Diligence Obligations Regarding Unlicensed Insurance Entities
Key Takeaways The Louisiana Insurance Department issued Bulletin 2026-07 reminding TPAs of their due diligence obligations when entering into agreements with entities offering insurance products or insurance services in Louisiana, following reports of unlicensed insurance activity in the state. The Bulletin signals increased regulatory scrutiny of TPAs licensed in Louisiana involved in insurance arrangements with unlicensed entities. TPAs may face enforcement actions in Louisiana for working with unlicensed entities. TPAs should exercise appropriate due diligence when entering into agreements with insurers or entities offering insurance products or related insurance services to verify that entities they are contracting with are properly licensed to conduct insurance business in Louisiana and that their TPA agreements comply with applicable Louisiana law. Louisiana insurance regulators are focusing on the
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Missouri Attorney General Files Suit Against Pharmacy Benefit Managers and Drug Manufacturers for Alleged Insulin Pricing Scheme
Key Takeaways The Missouri AG filed suit in St. Louis County Circuit Court against several PBMs and drug manufacturers, alleging they conspired to manipulate Missouri’s health care market and unlawfully drive up insulin prices. The AG’s office seeks restitution and damages for affected consumers, injunctive relief to halt the alleged practices and a finding of unjust enrichment by the Defendants. Missouri Attorney General Catherine Hanaway recently filed suit against a number of Pharmacy Benefit Manager (PBM) companies and drug manufacturers (collectively, the Defendants) doing business in Missouri. According to the Missouri Attorney General's (AG) office, the Defendants have allegedly manipulated Missouri's health care markets, resulting in a significant increase in the price of insulin medication. The Missouri AG's lawsuit, filed in St. Louis County
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