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New Indiana Insurance Department Bulletin Changes TPA Licensing and TPA Renewals

A recent Indiana Department of Insurance Bulletin announces a change regarding how the Department will issue initial third party administrator licenses and renew existing licenses for nonresident third party administrators in Indiana. The change came on March 2 when Indiana Insurance Commissioner Stephen Robertson issued Bulletin 236.

Under IC 27-1-25-12.2, a nonresident administrator is not eligible for a nonresident administrator license unless the nonresident administrator is licensed as a resident administrator in a home state that has TPA laws or regulations that are substantially similar to Indiana's TPA law.

The Department conducted a review of all TPA laws in the U.S. to determine which states' TPA laws are substantially similar to Indiana's TPA laws pursuant to IC 27-1-25. As a result of its review, the Department has concluded that only the following eight states have TPA laws that are substantially similar to Indiana's:

  • Alaska

  • Delaware

  • Florida

  • Idaho

  • Missouri

  • New Hampshire

  • New Jersey

  • West Virginia

Bulletin 236 indicates that a TPA applying for a nonresident TPA license in Indiana must provide a certificate of good standing from one of these eight states verifying that the TPA holds a resident TPA license in one of these eight states.

Bulletin 236 goes on to provide that if a TPA is not incorporated or does not maintain its principal place of business in one of these eight states, the TPA may either: (1) Declare Indiana as its "home state" and apply for a resident Indiana administrator license, or (2) Declare one of the eight states as its "home state," obtain a resident TPA license in that state, and apply for an Indiana nonresident administrator license.

Finally, Bulletin 236 indicates that as of July 1, 2017, the Department will not renew administrator licenses for nonresident administrators holding resident "home state" licenses in states other than the above-listed eight states. The Department will consider exceptions to this requirement for no more than one renewal and upon request from a nonresident administrator with good cause shown to the Department.

© Polsinelli PC, Polsinelli LLP in California


About this Author

Steven L. Imber, Polsinelli PC, Insurance Regulatory Attorney, Enforcement Actions Lawyer,

Steve Imber chairs Polsinelli's Insurance Business and Regulatory group.  As a former General Counsel at a state insurance department, Steve Imber has the knowledge and experience to provide quality counsel to insurers, third party administrators, insurance agencies, medical discount plans and other insurance regulated entities. His practice includes representing and assisting clients on multi-state and national licensing projects, research projects, enforcement actions, market conduct examinations, audits and compliance programs and various other regulatory and...


Justin Liby has a talent for organizing and managing large national and multi-state licensure and research projects. This knack provides him with a solid foundation for crafting and implementing sound, efficient strategies that achieve success for his clients. Justin concentrates his efforts on helping the insurance industry navigate the formidable federal and state regulatory maze to achieve the industry’s business needs. He stays current in the insurance industry's evolution, as well as the legislation and regulatory activity impacting the industry.

Justin is a former regulator for the Kansas Insurance Department and in-house counsel for a national third-party administrator.


Jennifer Osborn Nix works diligently for insurance companies, third-party administrators, and other regulated entities to further their goals and help them remain compliant within the 50-state regulatory scheme. She focuses on insurance regulatory and compliance issues, with a primary emphasis on life and health insurance matters.

Jennifer works with many regulated entities, including many in the health care sector, who rely on her for research, advice, strategic counsel, and licensing.