Washington Technical Assistance Advisory on Healthcare Benefit Manager Registration and Filing Mandates

October 07, 2025

On September 15, 2025, the Washington Office of Insurance (OIC) Commissioner issued Technical Assistance Advisory 2025-02. The Technical Assistance Advisory (TAA) provides guidance on Washington's healthcare benefit manager (HCBM) mandates.

Under Washington law, HCBMs are required to initially register with the OIC commissioner and annually renew their registration. HCBMs also must file with the OIC all benefit management contracts and contract amendments between the HCBM and a health carrier, provider, pharmacy, pharmacy services administration organization, or other healthcare benefit manager, entered directly or indirectly in support of a contract with a carrier or employee benefits programs.

HCBMS are generally defined by Washington mandates as a person or entity providing services to, or acting on behalf of, a health carrier or employee benefits programs, that directly or indirectly impacts the determination or utilization of benefits for, or patient access to, healthcare services, drugs, and supplies.

The TAA provides guidance on several points, including:

• Entities that are not included in the definition of HCBMs. For example, an employer administering its employee benefit plan or the employee benefit plan of an affiliated employer under common management and control.
• That HCBM requirements are inapplicable to persons or entities providing services to, or acting on behalf of, a union or employer administering a self-funded group health plan governed by the provisions of ERISA unless the self-funded private group health plan chooses to participate. The OIC will implement an opt-in process during Fall 2025 and make a list of the health plans that have opted in available on its website by December 1, 2025.

Employers with plans governed by state laws should be aware of these mandates and can contact their carrier for further details.

Read the full advisory here: Technical Assistance Advisory 2025-02 - OIC's Interpretation of Chapter 48.200 RCW – Healthcare Benefit Managers