The Indiana Department of Insurance (“Department”) has recently issued Bulletin 278 regarding new notification requirements applicable to all insurers, third party administrators (“TPAs”), and pharmacy benefit managers (“PBMs”). The key highlights are as follows:
Beginning July 1, 2025, and each July 1 thereafter, each insurer, TPA, and PBM doing business in Indiana shall file with the Department a report that includes the following information:
1. The name of each person or entity that has:
- an ownership interest of at least five percent (5%);
- a controlling interest; or
- an interest as a private equity partner
2. The business address of each person or entity identified in item (1), above.
3. The business website, if applicable, of each person or entity identified in item (I), above.
4. Any of the following identification numbers, if applicable, for a person or entity identified under item (I), above:
- National provider identifier (NPI).
- Taxpayer identification number (TIN).
- Employer identification number (EIN).
- CMS certification number (CCN).
- National Association of Insurance Commissioners (NAIC) identification number.
- A personal identification number associated with a license issued by the Department.
5. The ownership stake of each person or entity identified under item (I), above.
- The report provided may not include Social Security numbers of any individual.
- The Department may assess a fine of one thousand dollars ($1,000) per day for which a report is past due and the Department may take disciplinary action for repeat violations.
Please note that although this Bulletin becomes effective on July 1, 2025, Indiana has said there will be a “grace period” for initial reports which are due July 1, 2025 (without defining the “grace period”).
For any questions related to the above referenced bulletin in Indiana, please contact Westmont Associates!