Under Rule I-2021-01, effective July 1, 2022, Third Party Administrators (TPAs) require licensure to operate in Vermont. Under the Rule, TPAs are defined as entities that directly or indirectly underwrite, collect charges or premiums from, or adjust or settle claims for Vermont resident with respect to the following lines:
- Health, including, stop-loss coverage, health reimbursement arrangements (HRAs), flexible spending accounts (FSAs), and health savings accounts (HSAs) or similar tax-advantaged accounts for health-related expenses.
Licensed insurers and administrators of workers’ compensation lines are not required to apply for licensure as a TPA.
An entity that meets the definition of a “third party administrator” under Green Mountain Care Board Rule 8.000 (available here: Rule 8.000: Data Submission) is required to register with the Green Mountain Care Board as a reporting entity to the state’s all payer claims database, known as VHCURES. Registration is required annually, between November 1 and December 31. Currently both annual registration and VHCURES reporting occurs via Onpoint Health Data, GMCB’s contractor for health care claims data collection, consolidation, and user support.
Entities licensed in the United States to write life, annuity, health, or stop-loss coverage as an insurance company, health maintenance organization, fraternal benefit society, multiple employer welfare arrangement (MEWA), professional employer organization (PEO), or prepaid hospital or medical care plan are not required to obtain a TPA license in Vermont.
Entities seeking licensure shall apply for an initial application for licensure to operate in Vermont and pay a non-refundable fee of $600. Make checks payable to Department of Financial Regulation. Entities renewing their license will be assessed a fee of $600 every three years following initial licensure. Annual reporting required by the Rule is due on July 1 of each year.
Additional information about the Rule and the NAIC uniform application may be found at the links below:
- Third Party Administrators Rule
- Third Party Administrators FAQs
- Uniform Application for Third Party Administrator License
Annual Report requirements are due by July 1st.
Please mail applications, supporting materials, and annual reporting to:
Department of Financial Regulation
Insurance Division, Company Licensing
89 Main Street
Montpelier, VT 05620
Or email to: DFR.CompLic@vermont.gov