Registration for Third Party Administrators and Pharmacy Benefits Managers


Under Vermont laws and regulations, health insurers providing services to Vermont residents are required to register on an annual basis, by December 31st, with the State of Vermont. This requirement pertains to comprehensive major medical health benefit plans that may be insured or self-insured, Medicare Supplement, and Medicare Parts C and D. The instructions will guide registrants to the on-line registration form hosted by the State’s contractor Onpoint Health Data.

  • UPDATE: The March 1, 2016, U.S. Supreme Court decision Gobeille v. Liberty Mut. Ins. Co., 136 S. Ct. 936 (2016), affects the Green Mountain Care Board’s authority to mandate certain data reporting for the claims databases. The decision does not affect state TPA registration or licensing laws, including the Vermont TPA registration requirement.  TPA licensing and registration laws long precede the development of APCDs and the registration requirements were not examined by the Court in Gobeille; the Gobeille decision does not pertain to the licensing or registration requirements imposed by more than 40 states.  In Vermont, “[a]ny person or entity that provides third party administration services, a third party administrator or ‘TPA’ . . . , shall register . . ., both before doing business in Vermont and on an annual basis prior to December 31 thereafter.”  Regulation H-2008-01, § 3(B).  All TPAs that conduct business in Vermont must continue to register with the GMCB and must renew that registration on an annual basis. 

    --March 31, 2016

Pharmacy Benefit Manager (PBM) Disclosure Form

Under 18 V.S.A. §9472(d), pharmacy benefit managers (PBMs) that provide pharmacy benefit management for health plans in Vermont are required to report to the health insurer, as well as the Department of Financial Regulation (DFR) and the Green Mountain Care Board (GMCB) (collectively, “the State”) on the aggregate amount the pharmacy benefit manager retained on all claims charged to the health insurer for prescriptions filled during the preceding calendar year in excess of the amount the pharmacy benefit manager reimbursed pharmacies. This disclosure form has been developed to provide a standardized and consistent means by which PBMs may implement this statutory requirement with respect the disclosures required to the State. This form does not contemplate nor make recommendations on how PBMs may seek to fulfill their obligation to report this information to the health insurers they conduct business with.

For the purposes of this form, the disclosure information provided should be pertinent to:

  • Health insurers that are licensed in Vermont
  • PBM services provided to Vermont members only
  • Claims charged for the date range of January 1 to December 31 for the calendar year preceding the July 1 due date for the report

PBMs should complete the PBM Disclosure Form, convert to a portable document format (PDF), and route the completed forms, or any questions regarding them, to and

Registered Entities Lists

Pharmacy Benefit Managers,   October 23, 2017

Third Party Administrators,    October 23, 2017

Health Care Insurance Carriers, October 23, 2017

Health Care Claims Tax

Health insurers, third party administrators (TPA), and pharmacy benefit managers (PBM) providing services to Vermont residents are required to pay the Health Care Claims Tax to the Vermont Department of Taxes. The Annual Paid Claims and Enrollment Report (APCER) created from data collected by Health Insurers in the Vermont Health Care Uniform VHCURES provides the most current fiscal year paid claims data available. Insurers subject to the Health Care Claims Tax who are not submitting data to VHCURES are required to self-report their annual paid claims amount to the Vermont Department of Taxes. For additional information, contact:

Sharon Asay
Director of Taxpayer Services
Vermont Department of Taxes
Phone: 802-828-6808

Data Submission Information

Special Notice

Annual Statement Supplemental Reports (ASSR)

Contact Us

Green Mountain Care Board
3rd Floor City Center
89 Main Street
Montpelier, Vermont 05620-3601


How to Make a Public Comment