SC| South Carolina Department of Insurance Bulletin 2026-09 explains that, effective May 19, 2026, entities that administer qualifying self-insured wellness medical reimbursement programs must be licensed as Wellness Reimbursement Program Administrators (WRPAs) under S.C. Code Ann. § 38-105-10 et seq. The bulletin defines the types of ancillary health-plan reimbursement arrangements covered, distinguishes exempt wellness programs offered directly by individual or group health plans, and establishes detailed initial licensing, renewal, reporting, form-approval, recordkeeping, and enforcement expectations. It is regulatory guidance rather than legal advice.
- Initial licensure: Applicants must complete the Department’s online application and checklist, pay a nonrefundable $5,000 fee, demonstrate fitness and financial responsibility, provide ERISA-related attestation or federal approval documentation, submit two years of certified financials, maintain a surety bond of at least $75,000 or 10% of prior-year tax-deferred funds (whichever is greater), and furnish organizational, governance, biographical, program-contract, pricing, marketing, disclosure, employer, and South Carolina good-standing documentation.
- Renewal and ongoing obligations: Licenses expire each November 30, with the renewal period opening August 30; the ordinary annual renewal fee is $500. Licensees must report material changes within 30 days, obtain Department approval before issuing or changing program documents, advertising, or pricing, maintain complete business records for examination at least every three years, and provide specified notice, defense, indemnity, and documentation if a program produces a taxable event for an employer or employee.
- Noncompliance consequences: Missing the renewal deadline causes the license to expire or become inactive, generally requiring a new initial application and $5,000 fee to resume licensure. Operating without a WRPA license can result in administrative fines of up to $20,000 per violation, potential license suspension or revocation, separate penalties of up to $1,000 per offense in lieu of suspension/revocation, criminal prosecution and imprisonment, and a two-year waiting period to reapply after a denial, suspension, or revocation.