Around the PIA Western Alliance States -  Week of November 3, 2025

California — Lara Implements Climate Disaster Regulation: In a proactive effort to secure the financial stability of Californians, Commissioner Ricardo Lara has announced a groundbreaking regulation aimed at mitigating rising costs and safeguarding the nation's largest insurance market from ongoing catastrophic risks and technological threats. The Long-Term Solvency Regulation will provide the California Department of Insurance with enhanced oversight tools to protect from risks that may arise in the coming years or even decades.

“Regulators around the globe are facing significant challenges due to rapidly changing climate conditions, which impact market stability and affect both affordability and availability. Technological advancements are advancing faster than our departmental resources, highlighting the shortcomings of our outdated regulatory frameworks,” said Commissioner Lara. “In this rapidly evolving landscape, we must expect the unexpected. It is crucial to anticipate future risks to improve preparedness and mitigation efforts, as well as to ensure that companies can meet their legal obligations to consumers.”

The Long-Term Solvency Regulation aligns with the Commissioner’s work as a member of the International Association of Insurance Supervisors (IAIS), where he contributed to the development of guidance for insurance supervisors on climate risks, as well as various reports and standards. The regulation focuses on solvency strategies and leverages the growing implementation of standardized climate risk disclosures by regulators worldwide, alongside UN-led efforts to establish the Principles for Sustainable Insurance and the Sustainable Development Goals.

Why it matters

Using global tools to safeguard Californians: Financial regulators from the Banque de France, the Bank of England, the Bank of the Netherlands, Canada’s chief insurance regulator, and the Monetary Authority of Singapore have participated in scenario analysis exercises. This presents an opportunity for enhanced collaboration among regulators to promote sustainability in insurance markets and to develop frameworks for addressing emerging risks. As the largest sub-national insurance market in the world, California's regulator must actively engage and secure a seat at the table in global discussions on long-term risk analysis and solvency.

Robust financial oversight is essential for the security of Californians: The Department of Insurance supervises California-based insurance companies to ensure their stability and capacity to meet future obligations. According to the draft regulatory text released today, these companies must provide information to the Department to strengthen consumer protection against unforeseen challenges. Over the past three years, Commissioner Lara has contributed to the technical guidance of the IAIS climate risk framework, which has informed this proposed regulation as well as existing regulations in Europe for the banking industry.

New information on impact of climate and technology: Insurance companies are significant institutional investors in the U.S., with approximately $8.2 trillion in assets reported in 2022. Their investment performance directly influences their capacity to underwrite new policies. The Long-Term Solvency Regulation requires documentation of risks and opportunities projected for 2030, 2040, and 2050, which could impact underwriting, investments, or operations.

Addressing cybersecurity and artificial intelligence: The regulation will also address the evolving landscape of cybersecurity, focusing on data quality, the use of large datasets, and artificial intelligence.

Mitigating catastrophic risk: Companies will be required to share information on strategies to mitigate climate-related risks, such as extreme weather patterns and gradual market shifts expected to become pronounced by 2050. These risks include sea-level rise, changes in land use, and variations in water availability and agricultural productivity.

Enhancing stability amid transitions: The regulation will require information on transition risks associated with new technologies, particularly regarding the reduction of reliance on greenhouse gas-emitting technologies. Central to this effort are "stress tests" of climate risk scenarios for 2030, 2040, and 2050.

"In this new era of increasing risks, the role of the insurance industry must evolve from serving as a passive safety net to becoming a proactive enabler of resilience," said Daniel Murphy, Lead Financial Services Industry Partnerships & Climate Risk and Resilience Initiatives at the World Economic Forum. "Insurance regulators can help by encouraging long-range planning to better anticipate shocks before they lead to insurance crises for consumers."

“Managing climate risk is part and parcel of good risk management and of disaster risk reduction—but the past alone is not a reliable indicator of the future. This is why it is essential for insurers to assess different climate futures and their implications for their underwriting and investment portfolios,” said Butch Bacani, Head of Insurance at the UN Environment Programme and Chair of the UN Forum for Insurance Transition. “By insuring and investing with foresight, insurers are better positioned to enhance long-term business resilience and company value, close the protection gap, contribute to financial stability, and support the transition to safer, more resilient and sustainable communities and economies.”

“Scenario analysis is a critical risk management tool for navigating uncertainty,” said Dr. Sean Carmody, Executive Director, Policy and Advice Division of the Australian Prudential Regulation Authority, the country’s insurance regulator. “It helps institutions anticipate and prepare for emerging risks—such as the impact of a changing climate and rapid technological innovation—by exploring a range of plausible futures and identifying areas of vulnerability and strategies that can strengthen resilience in the financial system.”

“With climate change escalating the risks of weather-related extreme events and new technology bringing uncertainty to markets, long-term planning by insurance regulators is needed,” said Carolyn Kousky, Associate Vice President, Economics and Policy Analysis, at Environmental Defense Fund. “In order to preserve market stability, we must think longer term about the impacts of growing risks and the investments being made to mitigate them. To prevent surprises that can harm consumers, we need to be planning for a future that will look different from our past.”

"Insurers play a crucial role in global markets and have a profound effect on our economies. As regulators, we need to be better equipped to navigate an uncertain future," stated Commissioner Lara. "This regulation embodies my insights gained over the years, alongside those of my international regulatory colleagues. Together, we confront ongoing challenges, including climate disasters, technological changes, data constraints, and the urgent need for modern oversight and regulatory reform to safeguard our consumers and markets."

The Department of Insurance released draft regulatory text and will hold a workshop on November 14, 2025, to hear input from the public.

Idaho — Post Falls Woman Sentenced for Insurance Fraud: On July 9, 2025, a Post Falls jury found Michelle Stone guilty of two felony counts of insurance fraud. The Idaho Department of Insurance Fraud Unit investigated the fraud.

Stone’s conviction stems from her report of an alleged burglary to the Post Falls Police Department. Stone then filed a fraudulent-insurance claim with Allstate Insurance and supplied photographs to support the alleged burglary. Investigators determined that the photographs Stone provided were taken after the reported burglary date.

On October 14, 2025, the Kootenai County District Court sentenced Stone to:

Up to five years in prison, suspended in favor of supervised probation

150 hours of community service

Payment of court costs, fines, and restitution

“This case demonstrates the importance of thorough investigation and cooperation between law enforcement and the Department of Insurance,” said Dean Cameron, Director of the Idaho Department of Insurance. “Insurance fraud is a serious crime that affects every honest policyholder through higher premiums.”

The Idaho Department of Insurance encourages anyone who suspects insurance fraud to report it online at doi.idaho.gov or by calling 1-866-939-7226.

Idaho — Josh Masterson Promoted to Chief Deputy State Fire Marshal: The Idaho State Fire Marshal’s Office is proud to announce the promotion of Josh Masterson to the position of Chief Deputy State Fire Marshal. This well-earned advancement recognizes Masterson’s outstanding service, dedication, and professional achievements within the State Fire Marshal’s Office over the past three years.

Masterson brings a wealth of experience and expertise to his new role. He holds multiple certifications, including Certified Fire Investigator with the International Association of Arson Investigators, Certified Fire & Explosion Investigator with the National Association of Fire and Explosion Investigators, and Certified Fire Inspector I through the International Code Council. He also earned an associate’s degree in Fire Science from Purdue University.

A U.S. Marine Corps veteran and Purple Heart recipient, Josh served honorably during Operation Enduring Freedom in Afghanistan. Following his military service, he joined the St. Maries Fire District, where he rose to the rank of Deputy Chief before joining the State Fire Marshal’s Office.

“We are fortunate to have Josh,” said State Fire Marshal Knute Sandahl. “Josh brings a level of discipline, tenacity, and professionalism to our dedicated office. He will continue this tradition in North Idaho, where he is assigned.”

Masterson’s promotion reflects the State Fire Marshal’s commitment to excellence in fire prevention, investigation, and public safety across Idaho.

Oregon — The Oregon Division of Financial Regulation recently announced the following proposed rulemaking: Filing Caption: Adopt requirement for Consumer-Friendly Summary Document in rate filing 

Rule Proposed: 836-053-0480

Rule Summary: Adopting required consumer friendly summary document for rate filings.

Filed: October 28, 2025

Hearing Date/Time: November 20, 2025, 11 AM

This is a virtual meeting conducted via Microsoft Teams.

Last day/time to offer comment: Dec 1, 2025, 5 PM 

Oregon — The Oregon Division of Financial Regulation recently announced the following permanent rulemaking: ID 7-2025: Oregon election to opt-out from two Interstate Insurance Product Regulation Compact Uniform

Standards

Rule: 836-080-0195

Summary: This rule exercises the opt-out provisions of the Interstate Insurance Product Regulation Compact

(Compact). The director of the Department of Consumer and Business Services considered and found the protections

offered to Oregon residents from following Compact Uniform Standards are not adequate:

1) Standards for Individual Deferred Index Linked Variable Annuity Contracts; and

2) Additional Standards for Market Value Adjustment Feature for Modified Guaranteed Annuities and Index-Linked

Variable Annuities.

Filed: October 28, 2025

Effective: November 1, 2025

Washington — Kuderer issues more than $820,000 in fines for insurance violations: Washington state Insurance Commissioner Patty Kuderer issued fines totaling $828,500 for insurance law violations in July, August, September, and early October of 2025. That included a $100,000 fine for Regence BlueShield, which incorrectly denied 954 claims for treatment, and a $550,000 fine against Premera — announced in August — for violations of the Health Parity and Addiction Equity Act and Washington’s provider directory regulations.

The third-quarter total brings the amount collected since 2001 to over $44 million, which the Office of the Insurance Commissioner (OIC) sends to the state’s general fund to pay for state services.

Regence fined $100,000 for incorrectly denying claims

Kuderer fined Regence Blueshield $100,000 for incorrectly denying 954 claims for treatment based on a lack of preauthorization. The denials took place between June 11, 2020, and May 25, 2022, and included chiropractic, physical therapy, occupational therapy, acupuncture and Eastern medicine, massage therapy, and speech and hearing therapies.

Regence reprocessed the claims, after which Regence’s amount paid increased from $11,139 to $85,982. The patient portion also increased — from $6,114 to $31,724 — after reprocessing because policyholder cost-shares and deductibles were now applied.

Additional fines

Jonathan Ayers, Vancouver, Wash.; fined $3,000 (order 25-0099).

    Ayers lowered the deductible on a policy for his own travel trailer from $1,000 to $250 and misrepresented the date of the loss on a claim filed under the policy. The consent order imposed two years of probation, bars him from acting as the agent on his own policies for two years, and requires Ayers to complete 10 hours of ethics training within one year of the order. 

Dentegra Insurance Company, Wilmington, Del.; fined $75,000 (order 25-0102).

    Dentegra failed to timely file its 2026 dental network access plan and GeoNetwork reports, placing approximately 11,000 enrollees at risk of coverage disruption or loss.

    Dentegra was fined $75,000 and agreed to cover at least $25,000 in basic dental care and services, including preventive cleanings and checkups, as well as basic restorative services, for uninsured Washingtonians by January 14, 2026.

PacificSource Health Plans, Springfield, Ore.; fined $25,000 (order 25-0054).

    Due to a system coding error, PacificSource issued adverse benefit determinations that didn’t disclose members’ appeal rights on prescription drug denials for 116 members.

Midvale Indemnity Company, Madison, Wis.; fined $5,000 (order 25-0079).

    Midvale incorrectly applied rating factors on 233 business policies in effect in 2023. The company returned, with interest, the $461 in resulting overcharges and waived $6,619 in resulting undercharges.

Heartland Dental LLC, Wilmington, Del.; fined $15,000 (order 25-0100).

    Heartland failed to timely report health care benefit manager credentialing contracts with 17 carriers.

KeyCorp Insurance Agency USA, Inc., Brooklyn, Ohio; fined $10,000 (order 25-0065).

    KeyCorp failed to competently and timely resolve an identified annuity issue, failed to competently oversee two of its affiliated producers, and conducted business under something other than its legal name.

Premera Blue Cross, Mountlake Terrace, Wash.; fined $550,000 (order 24-0108).

    Premera was fined for violations of the Mental Health Parity and Addiction Equity Act and Washington’s provider directory regulations.

Prestige International Insurance Group, Tamarac, Fla.; fined $1,000 (order 25-0095).

    Prestige failed to notify an insurance company, and required an additional form to be signed upon receiving a customer’s request to cancel their policy.

The Corporation of Haverford College, Haverford, Penn.; fined $12,500 (order 25-0122).

    The college issued five charitable gift annuities in Washington from 1993 to 2021 — with an aggregate value of $501,317 — before obtaining a certificate of exemption from the OIC and issued annuities that didn’t comply with state law.

Eagle West Insurance Company, Monterey, Calif.; fined $5,000 (order 25-0103).

    Eagle West used incorrect base rates for its 680 Washington commercial farm and ranch policies in the first five months of 2023. The company waived $261,673 in undercharged premiums on 315 policies and refunded $559 in overpayments on nine policies.

Accredited Surety and Casualty Company, Orlando, Fla.; fined $15,000 (order 25-0126).

    The company issued ocean marine insurance policies without being authorized for that line of insurance in Washington state.

Grange Insurance Association, Seattle, Wash.; fined $5,000 (order 25-0107).

    The company applied incorrect protection classification codes to an estimated 149 farm policies in 2023 and 2024, resulting in an estimated $133,206 in undercharged premiums. 

Ying Sun, Bellevue, Wash.; fined $5,000 (order 25-0136).

    Sun made false statements on 12 submitted applications for life insurance policies, stating the applications were signed in various California cities when they were actually signed in Washington. The consent order also imposed two years of probation, including a requirement that Sun have a mentor review their insurance work in Washington during the probation.

Bankers Fidelity Life Insurance Company, Atlanta, Ga.; fined $2,000 (order 25-0146).

    The company filed its annual Medicare Supplement Premium Rates and Experience form and its annual Medicare Supplement Refund Calculation form after the deadline of May 31, 2024.

Washington — Plan Year 2026 Uniform Cost-Sharing Reduction Factor – Extension of Emergency Rule: On March 10, 2025, the Commissioner adopted an emergency rule (WSR 25-07-021) related to cost-sharing reduction (CSR) silver loading that is applicable to Plan Year 2026 health insurer rate filings. This emergency rule adjusts health insurer rate development components to preserve consumer affordability and stability in Washington state’s individual health insurance market. The emergency rule achieves this by applying a uniform CSR silver load adjustment factor to rates for silver level qualified health plans sold on the Washington state Health Benefit Exchange.

On June 29, 2025, the Commissioner extended this emergency rule under WSR 25-07-070, which RCW 34.05.350 allows.

The Commissioner is extending this emergency rule again to continue to preserve consumer affordability and stability in Washington state’s individual health insurance market for Plan Year 2026. 

OIC has initiated notice and comment rulemaking on this issue in WSR 25-13-098, to provide insurers rate development instructions beginning in Plan Year 2027.  

Please contact rulescoordinator@oic.wa.gov with any questions regarding this GovDelivery communication.

For more information, including the adopted emergency rule (CR-103E), please visit the rule webpage.

Washington — Patty’s Takes: Congress must act now to support people buying their own health insurance: Washington’s individual health insurance market opens for enrollment tomorrow. Normally this event gets local attention, but today the fate of the federal government’s shut down is hanging on whether the Republican-controlled Congress will continue the enhanced tax credits millions of consumers rely on to afford coverage.

About 300,000 Washingtonians shop for individual health insurance on our Exchange, Washington Healthplanfinder and do so because their employer doesn’t offer coverage, they’re self-employed or they retired early and are too young for Medicare. And nearly 217,000 of these consumers qualified for tax credits last year to help them afford coverage for themselves and their families.

This year we approved 14 health insurers to sell plans across the state and partnered with our Exchange to take every step possible within our authority, including issuing a rule to lessen the impact of premium increases or losing federal funding for tax credits on policyholders.

This rule is why some people shopping on the Exchange may find a lower cost/higher benefit plan this year or why some people may see a larger tax credit.

I know these actions are not enough and many people are now deciding if they can afford to keep coverage this year.

Every year, health insurers request rate changes for their plans in the individual market. This year, we approved a 21% rate increase, and I know that news hit consumers hard. Unfortunately, our authority over rate changes health insurers request is very limited. If they can show how an increase is actuarially justified, we’re required by state law to accept the change.

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The enhanced tax credits were established in 2021 to help people afford insurance and were extended to 2025 a year later. The data tells us that the enhanced tax credits have been quite successful at increasing access to insurance — and helped bring Washington’s uninsured rate down to a historic low of only 4.8%. That benefits everyone. Unfortunately, if Congress does not act now, they will expire at the end of the year.

It doesn’t have to be this way.

I’ve joined members of our Congressional delegation over the last several weeks, making the case for immediate extension of these enhanced tax credits and I will continue to do so. I’ve laid out what’s at stake: An estimated 80,000 people will likely go without health insurance if Congress does not take immediate action. And this will hit older people and our rural communities harder.

Our country’s health insurance system is far from perfect, and the Affordable Care Act is not the answer to all its problems. But it was a critical first step in a long road of reforms needed and it increased access to coverage for roughly 900,000 people in Washington. It should be strengthened, not destroyed.

Health care is very personal to me and it’s why I ran for this office. Just like many of you, I have my own story of fighting an insurance denial that put my family’s health at risk. It’s why I believe health care is a human right. And I don’t believe we should be using people and their families’ health and financial stability as political pawns.

If you’re lucky enough to have insurance through your job, like I do, and like millions of Americans do (including members of Congress and the President), you cannot imagine the fear that people face when their premiums rise out of reach, or they put off getting care, worrying about getting one bad diagnosis that forces them into bankruptcy.

It’s not too late, but it’s close.

Knowing what’s a stake and failing to act is a dereliction of the highest duty of an elected official and of a body elected to do the peoples’ business. Americans deserve so much more.