I. The Amendment

On October 1, 2026, the Missouri Department of Commerce and Insurance (the Department) announced an amendment to a state administrative rule, 20 CSR 200-9.800 (the Rule), that “provides targeted regulatory relief for small and emerging third-party administrators (TPAs) operating in Missouri.” Effective September 30, the amended Rule “creates an exemption from mandatory independent audits by CPAs for qualifying small and newly established TPAs.” According to the Department, the amendment is intended to “significantly reduc[e] regulatory costs and administrative burden while fostering business growth across the state.”

The announcement describes TPAs as performing “vital behind-the-scenes functions for insurance companies handling life, health, annuities, and workers’ compensation lines.” Per the Department, TPAs are “[o]ften serving as the direct point of contact for Missourians when paying health insurance premiums or submitting claims documentation” and “are responsible for claims settlement, underwriting, premium collection and solicitation.” The Department reports that 492 licensed TPAs currently operate in Missouri.

II. The Prior Audit Requirement

Under Mo. Rev. Stat. Section 376.1093, “all licensed TPAs must submit an annual report to the department by March 1.” Per the announcement, “[p]reviously, administrative rules required every TPA, regardless of size or operating revenue, to submit an independently audited financial statement prepared by a CPA.” The Department notes that, “[w]hile valuable for verifying financial stability, independent audits impose recurring costs that place a disproportionate burden on smaller and newer enterprises.”

III. Exemption Criteria

The amended Rule exempts “independent TPAs (those not operating as part of an insurance holding company system)” from the CPA audit requirement if they meet at least one of the following:

1. Asset Threshold: Report “less than $1,000,000 in total assets during the most recent fiscal year”;
2. Revenue Threshold: Report “less than $5,000,000 in total revenue during the most recent fiscal year”; or
3. Emerging Businesses: Have “been in continuous operation for fewer than two fiscal years.”

IV. Continuing Filing Obligations

The exemption does not eliminate financial reporting altogether. Per the announcement, “[q]ualifying small TPAs will continue to submit officer-certified financial statements alongside their mandatory annual filings, ensuring continued transparency and accountability.” By contrast, “TPAs affiliated with larger insurance holding companies will continue to provide full audited financial statements.”

V. Conclusion

Under the amended Rule, an independent TPA that reports less than $1 million in total assets or less than $5 million in total revenue for its most recent fiscal year, or that has been in continuous operation for fewer than two fiscal years, is no longer required to submit a CPA-audited financial statement. Such TPAs must instead submit officer-certified financial statements alongside the annual report required under Mo. Rev. Stat. Section 376.1093, which is due by March 1. TPAs affiliated with insurance holding company systems remain subject to the requirement to provide full audited financial statements.