Around the PIA Western Alliance States – Week of December 15, 2025
Published December 16, 2025 at 11:41 AM · News Releases and Bulletins
Idaho — Idaho Department of Insurance Earns NAIC Accreditation for Regulatory Excellence: The Idaho Department of Insurance has once again earned accreditation from the National Association of Insurance Commissioners (NAIC), reaffirming its commitment to protecting Idaho consumers through strong financial oversight and regulatory excellence.
Accreditation ensures that Idaho maintains regulatory authority over its own insurance market, helping to keep companies based in-state. It reduces unnecessary regulatory costs, which helps keep premiums more affordable for consumers. It also strengthens Idaho’s appeal to insurers and ensures companies remain financially sound and able to pay claims.
“This accreditation is more than a regulatory milestone—it’s a promise to Idaho families, businesses, and communities that we are watching out for them,” said Director Dean Cameron. “When you pay your insurance premiums, you’re trusting that your insurer will be there when you need them most. Our accreditation means we have the tools, expertise, and oversight in place to help make sure that trust is well-placed.”
NAIC’s Financial Regulation Standards and Accreditation Committee voted to accredit Idaho, along with the insurance departments of Kentucky, Oklahoma and Vermont. This recognition follows a rigorous, independent review process conducted every five years to ensure state insurance departments meet the highest standards in financial solvency regulation.
“The NAIC Accreditation Program is a comprehensive and demanding process that ensures consistency and coordination among state regulators,” said Director Cameron. “This achievement reflects the dedication and professionalism of our team. I’m incredibly proud of their work in upholding these standards.”
The NAIC Accreditation Program was established to promote effective solvency regulation, particularly for insurers operating across multiple states. Accreditation ensures that state departments have the necessary laws, practices, and organizational expertise to monitor the financial health of insurance companies and protect policyholders.
To achieve accreditation, each state undergoes a full review by a team of independent consultants who assess compliance with NAIC standards. Their findings inform the committee’s final decision on accreditation status.
For more information about the Idaho Department of Insurance and its regulatory responsibilities, visit doi.idaho.gov.
Oregon — The Oregon Division of Financial Regulation recently announced the following permanent rulemaking:
ID 8-2025: Amending OAR 836-150-0040 to add ORP payment parameters for plan year 2026
Rule: 836-150-0040
Summary: The amended rule will include payment parameters for plan year 2026 (attachment point of $108,000; reinsurance cap of $1,000,000; and coinsurance rate of 50%), while deleting the provisions related to plan year 2021.
Filed: November 17, 2025
Effective: January 1, 2026
Oregon — The Oregon Division of Financial Regulation recently announced the following permanent rulemaking:
ID 9-2025: List of Prosthetic and Orthotic Devices under Oregon SB 699 (2025)
Rule: 836-052-1000
Summary: Establishes list of prosthetic and orthotic devices; prohibits internal or separate limits or caps on prosthetic and orthotic devices, other than the lifetime policy maximum, when permitted by law; defines when coverage for prosthetic and orthotic devices is provided through a managed care organization.
Filed: November 17, 2025
Effective: January 1, 2026
Oregon — The Oregon Division of Financial Regulation recently announced the following permanent rulemaking:
ID 10-2025: HB 3134 (2025) Prior Authorization Insurer Data Reporting Updates
Rule: 836-053-1070
Summary: Updates the rule to align with the prior authorization data reporting requirements in HB 3134 (2025), including:
•Amends the prior authorization aggregate data metrics to be reported to DCBS.
•Amends the prior authorization aggregate data reporting due date from “on or before June 30” to “on or before January 31”.
•Adds statutory definitions of standard and expedited prior authorization requests.
•Updates statutory citations.
Filed: November 18, 2025
Effective: January 1, 2026
The Oregon Division of Financial Regulation recently announced the following permanent rulemaking:
ID 11-2025: 2025 Behavioral Health Parity Rule
Rule: 836-053-1430
Summary: This rule governs annual data reporting requirements for health insurers related to behavioral health
parity in Oregon. It implements changes required by SB 824 (2025), including:
•Restoring and making permanent the quantitative data reporting requirements for behavioral health parity.
•Adding confidentiality protections for carrier-submitted data.
•Updating statutory citations.
Filed: November 20, 2025
Effective: January 1, 2026
Oregon — The Oregon Division of Financial Regulation recently announced the following permanent rulemaking:
ID 12-2025: Revisions to NAIC accreditation standards and related model laws and regulations implementing SB 831 (2025)
Rules: 836-027-0005, 836-027-0150, 836-027-0160
Summary: Adds definition for “group capital calculation” and provides explanation of the concept of the “National Association of Insurance Commissioners liquidity stress test framework.” Creates a new rule that outlines the Insurance Commissioner’s discretion to determine exemptions from filing the annual group capital calculation. In relation to insurer requirements to give notice of proposed transactions pursuant to ORS 732.574, adds additional information regarding the data of an insurer that are subject to cost sharing and management services agreements; adds provisions related to access to staff and essential services during supervision, seizure, conservatorship, or receivership; adds provisions to extend certain affiliate commitments to a guaranty association, as appropriate, if the insurer is under supervision, seizure, conservatorship or receivership.
Filed: November 20, 2025
Effective: January 1, 2026
Oregon — To all insurance companies writing auto insurance in Oregon: The Oregon DMV requested that issuers of auto insurance policies be made aware of the following information. If you have questions, contact DMVDriverControl@odot.oregon.gov.
SB 840 Sections 41-47: Key Updates for Insurers
These provisions take effect January 1, 2026, and make changes to Oregon's financial responsibility and suspension laws related to uninsured driving and accidents:
Shortened SR-22 Filing Requirement for Driving Uninsured Conviction
Repeal of Mandatory Suspension for Uninsured Accidents
Required Statement from Insurer
How does this impact auto insurance issuers?
Insurers may want to inform their customers about the shortened SR-22 requirement and the repeal of mandatory uninsured accident suspensions.
Insurers should be prepared to provide a signed statement on company letterhead for DMV if asked by a customer.
Insurers may need to modify internal systems and workflows to reflect these changes.
Click here to review this memorandum: https://bit.ly/4al3wQn
Oregon — The Oregon Division of Financial Regulation recently announced the following permanent rulemaking:
ID 8-2025: Amending OAR 836-150-0040 to add ORP payment parameters for plan year 2026
Rule: 836-150-0040
Summary: The amended rule will include payment parameters for plan year 2026 (attachment point of $108,000; reinsurance cap of $1,000,000; and coinsurance rate of 50%), while deleting the provisions related to plan year 2021.
Filed: November 17, 2025
Effective: January 1, 2026
Oregon — The Oregon Division of Financial Regulation recently announced the following permanent rulemaking: ID 9-2025: List of Prosthetic and Orthotic Devices under Oregon SB 699 (2025)
Rule: 836-052-1000
Summary: Establishes list of prosthetic and orthotic devices; prohibits internal or separate limits or caps on prosthetic and orthotic devices, other than the lifetime policy maximum, when permitted by law; defines when coverage for prosthetic and orthotic devices is provided through a managed care organization.
Filed: November 17, 2025
Effective: January 1, 2026
Oregon — The Oregon Division of Financial Regulation recently announced the following permanent rulemaking:
ID 10-2025: HB 3134 (2025) Prior Authorization Insurer Data Reporting Updates
Rule: 836-053-1070
Summary: Updates the rule to align with the prior authorization data reporting requirements in HB 3134 (2025), including:
•Amends the prior authorization aggregate data metrics to be reported to DCBS.
•Amends the prior authorization aggregate data reporting due date from “on or before June 30” to “on or before January 31”.
•Adds statutory definitions of standard and expedited prior authorization requests.
•Updates statutory citations.
Filed: November 18, 2025
Effective: January 1, 2026
Oregon — The Oregon Division of Financial Regulation recently announced the following permanent rulemaking:
ID 11-2025: 2025 Behavioral Health Parity Rule
Rule: 836-053-1430
Summary: This rule governs annual data reporting requirements for health insurers related to behavioral health
parity in Oregon. It implements changes required by SB 824 (2025), including:
•Restoring and making permanent the quantitative data reporting requirements for behavioral health parity.
•Adding confidentiality protections for carrier-submitted data.
•Updating statutory citations.
Filed: November 20, 2025
Effective: January 1, 2026
Oregon — The Oregon Division of Financial Regulation recently announced the following permanent rulemaking:
ID 12-2025: Revisions to NAIC accreditation standards and related model laws and regulations implementing SB 831 (2025)
Rules: 836-027-0005, 836-027-0150, 836-027-0160
Summary: Adds definition for “group capital calculation” and provides explanation of the concept of the “National Association of Insurance Commissioners liquidity stress test framework.” Creates a new rule that outlines the Insurance Commissioner’s discretion to determine exemptions from filing the annual group capital calculation. In relation to insurer requirements to give notice of proposed transactions pursuant to ORS 732.574, adds additional information regarding the data of an insurer that are subject to cost sharing and management services agreements; adds provisions related to access to staff and essential services during supervision, seizure, conservatorship, or receivership; adds provisions to extend certain affiliate commitments to a guaranty association, as appropriate, if the insurer is under supervision, seizure, conservatorship or receivership.
Filed: November 20, 2025
Effective: January 1, 2026
Oregon — To all insurance companies writing auto insurance in Oregon,
The Oregon DMV requested that issuers of auto insurance policies be made aware of the following information. If you have questions, contact DMVDriverControl@odot.oregon.gov.
SB 840 Sections 41-47: Key Updates for Insurers
These provisions take effect January 1, 2026, and make changes to Oregon's financial responsibility and suspension laws related to uninsured driving and accidents:
Shortened SR-22 Filing Requirement for Driving Uninsured Conviction
Repeal of Mandatory Suspension for Uninsured Accidents
Required Statement from Insurer
How does this impact auto insurance issuers?
Insurers may want to inform their customers about the shortened SR-22 requirement and the repeal of mandatory uninsured accident suspensions.
Insurers should be prepared to provide a signed statement on company letterhead for DMV if asked by a customer.
Insurers may need to modify internal systems and workflows to reflect these changes.
Click here to review this memorandum: https://bit.ly/3MxLCAa
Washington — Emergency order 2025-01: Providing relief to Washington consumers from 2025 atmospheric river and winter weather event by addressing grace periods for nonpayment of premium and temporarily prohibiting cancellation and nonrenewal of property insurance policies
We are providing Emergency Order 2025-01 to insurance companies and other interested entities. The emergency order provides relief to Washington consumers from 2025 atmospheric river and winter weather event by addressing grace periods for nonpayment of premium and temporarily prohibiting cancellation and nonrenewal of property insurance policies
For more information, including other advisories, please visit the technical assistance advisories and emergency orders webpage.
Washington — Washington state Insurance Commissioner Patty Kuderer fined ClearShare Health, Clearwater Benefits LLC, and three related companies $350,000 on December 3 for selling unauthorized health insurance. Kuderer also ordered the companies to stop transacting unauthorized insurance, including selling ClearShare health plans in Washington.
Clearwater Benefits is a non-resident sales agency authorized to sell life and disability products in Washington that was also marketing and selling ClearShare Health plans. An inquiry through social media in 2023 prompted the staff of the Office of the Insurance Commissioner (OIC) to investigate whether ClearShare’s health plans were being sold legally.
ClearShare is a nonprofit corporation incorporated in April 2022 that markets itself as a health care sharing ministry. The company sold 376 memberships to Washington residents between August 1, 2022, and March 30, 2024. Around 200 of those were sold before ClearShare was exempted from federal income tax as a non-profit organization by the Internal Revenue Service, which was effective in February of 2023.
During OIC’s investigation, ClearShare reported it collected $524,095 in premiums from Washington members between August 2022 and March 2024, and paid $54,201 towards their medical expenses while denying another $54,535 in expenses.
ClearShare’s plans also included pre-existing condition exclusions. Other medical services — like abortion — that must be covered in accordance with state law weren’t covered.
By law, health care sharing ministries must meet a certain set of qualifications. That includes sharing medical expenses continuously since December 31, 1999, which ClearShare — incorporated in 2022 — has not. As the company was not, by definition, a health care sharing ministry and was not authorized to sell health insurance in Washington state, the companies were determined to be operating illegally and, as a result, are subject to fines of up to $25,000 per violation.
Kuderer also ordered ClearShare to pay taxes, including interest and penalties, on the premiums collected from Washington residents.
Final order issued on Unite Health Share Ministries
The OIC received a final order on its case against Unite Health Share Ministries and United Faith Ministries on November 6, 2025. OIC’s Presiding Officer ruled the companies did not meet the criteria to be classified as a health care sharing ministry and violated the Insurance Code by transacting insurance as unauthorized insurers. On December 8, 2025, the companies filed a petition seeking judicial review of the final order.
The agency opened an investigation after receiving a consumer complaint that Unite Health had only paid $5,000 on a medical claim, leaving them with almost $200,000 in medical bills remaining. The OIC issued a $300,000 fine and a cease-and-desist order in June of 2024.