John S. Conniff is an attorney admitted to practice in Washington and Oregon. He attended Seattle University undergraduate and earned his law degree from Seattle University. He served as counsel to the Washington State Legislature, was Deputy Insurance Commissioner for Health care and now practices law in his own firm concentrating on health, insurance, and business matters.

Another AHP Challenge to Insurance Commissioner

And now for something completely different. Since 2004, Washington State has required all self-funded Multiple Employer Welfare Arrangements (MEWAs) to obtain a certificate of authority to conduct business in the state. The statute imposes strict standards of eligibility and detours from federal ERISA interpretations of “bona fide association” with its own unique statutory definition: “Bona…

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Insurance Commissioner Proposes TPA Regulation

The Washington Insurance Commissioner has requested legislation for registration of third party administrators to protect consumers. Third party administrators (TPAs) come in all shapes and sizes and just as many flavors. Insurers typically provide most services for administration of its own health plans. Many Insurers also sell administrative services to self-funded plans which would make…

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Insurance Commissioner Explains AHP Settlement

The ranking member of the Washington State House Health Care Committee, Representative Joe Schmick, read my recent association health plan (AHP) post and shared the Insurance Commissioner’s letter explaining the agency’s recent actions. In his letter, the Commissioner addresses the administrative law judge’s decision disapproving the agency’s rating requirements. Disagreement over bona fide status was…

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Insurance Commissioner Settlement with AHPs

The Washington Insurance Commissioner’s Office (OIC) responded to my public disclosure request and released the settlement agreement signed by the Business Health Trusts (BHT) and Commissioner Kreidler on September 28, 2015. The Agreement includes two exhibits. Exhibit A which alphabetically lists employers in each of the 13 different associations comprising BHT and Exhibit B which…

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The Confusing Morass of Association Health Plan Regulation

Many folks have asked for explanations and guidance on the creation or continuation of association health plans (AHPs) in Washington State. The tortured history of AHP regulation in this state defies any imposition of rational thought, let alone legal explanation. Here’s one example that you can mull over while you’re parked on the interstate. Just…

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