An act relating to annual reporting on health care sharing plans and arrangements
S.132 would create a new annual reporting and certification requirement for persons that are not authorized to sell insurance in Vermont but offer or intend to offer health care sharing plans or arrangements to Vermont residents. These plans are typically arrangements that help participants pay or reimburse health care costs outside of traditional insurance regulation. The bill requires covered entities to submit detailed information to the Commissioner of Financial Regulation each year, beginning October 1, 2025, and then annually thereafter.
The required disclosures are extensive and include participation counts, employer-group participation, national enrollment, provider contracts in Vermont, fees collected and retained for administration, reimbursement requests and payments, denials and appeals, unpaid eligible claims, projected future participation, third-party marketers or administrators, licensed insurance producers involved, consumer-facing marketing materials, contact information, corporate affiliations, and organizational leadership. An officer must also certify that the submission is accurate to the best of the person’s good-faith knowledge and belief. The Commissioner must then publish an annual summary report on the department’s website, along with evidence-based consumer information and complaint instructions.
The bill would add 8 V.S.A. § 4078 and expand the Department of Financial Regulation’s oversight of health care sharing ministries or similar arrangements that operate outside Vermont’s insurance licensing framework. It creates a reporting regime, a completeness review process, administrative penalties of up to $5,000 per day for noncompliance, and the possibility of a cease-and-desist order if deficiencies are not corrected. It also authorizes the Commissioner to adopt implementing rules and requires public reporting, which could affect how these entities market, enroll, and administer plans for Vermont residents.
Based on the bill text and the absence of recorded committee testimony or votes in the provided materials, the apparent sentiment is regulatory and consumer-protection oriented rather than partisan or controversial on its face. The bill’s structure suggests concern about transparency, accountability, and public awareness regarding non-insurance health coverage arrangements. No formal vote history or transcript evidence is available here to indicate support or opposition from specific lawmakers or stakeholders.
The main likely point of contention is the scope of regulation over entities that are not licensed insurers but still facilitate payment for health care costs. Supporters would likely view the bill as a transparency measure that helps consumers understand what these arrangements do, how often claims are paid or denied, and whether marketing is accurate. Opponents may argue that the reporting burden is extensive, that the bill could chill participation or marketing, or that it treats faith-based or alternative sharing arrangements too much like insurance. The bill also reaches third-party marketers, licensed producers, and affiliated entities, which could raise concerns about compliance costs and administrative exposure.