May 24, 2020

May 22, 2020

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New Kansas Insurance Department Bulletin Changes TPA Licensing and TPA Renewals

On the heels of the Kansas Legislature’s recent adoption of Senate Bill No. 22 regarding third party administrators, the Kansas Insurance Department issued Bulletin 2017-2 to identify the states the Department has determined have substantially similar third party administrator laws to Kansas. 

Kansas Senate Bill No. 22 announced a change regarding how the Department will issue initial and renewal licenses for nonresident third party administrators in Kansas. Pursuant to Senate Bill No. 22, a person (an individual or business entity) that performs the duties of an administrator in Kansas must hold either a resident or a nonresident license.  A person is not eligible for a nonresident administrator license unless the person is licensed as a resident administrator in a home state that has a third party administrator law or regulation substantially similar to Kansas.

Bulletin 2017-2 was signed by Kansas Insurance Commissioner Ken Selzer on May 2nd, and the Bulletin states that the Department conducted a review of all TPA laws in the U.S. to determine which states’ TPA laws are substantially similar to Kansas’ TPA laws. As a result of its review, the Department has concluded that only the following eight states have TPA laws that are substantially similar to the Kansas law:

  • Alaska

  • Delaware

  • Florida

  • Idaho

  • Indiana

  • Missouri

  • New Hampshire

  • West Virginia

Bulletin 2017-2 indicates that beginning June 1, 2017, the Department will not renew nonresident administrator licenses for nonresident administrators holding resident licenses in states other than these eight states.

Bulletin 2017-2 also provides that beginning January 1, 2018, resident and nonresident administrators holding licenses in Kansas will need to renew their licenses on a biennial basis. The first biennial renewal will be due by December 31, 2018. Also, every administrator will be required to file annual reports with the Department on or before July 1 of each year, with the first annual report due on or before July 1, 2018.

© 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.