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Paula Flower’s letter to the TNSIA

To: TERRY HILL, TNSIA

Terry, I only recently became aware that the TNSIA had formed. As Commissioner of Commerce and Insurance, I dealt with many statutory, regulatory, and policy questions related to self-insurers, both individual and groups. I don’t know if you are also aware that the National Association of Insurance Commissioners also has various committees who draft model laws and regulations relating to self-insured risk, including third party administrators, loss reimbursement policies (“high deductible” policies), and general worker’s compensation matters. I recently made a presentation to fourteen self-insured trusts across the nation concerning the regulatory and legal implications of impaired self-insured groups.

I think the formation of the TNSIA is a great thing. As Commissioner I struggled to get input on self-insured matters because individual self-insured employers had no collective voice. Let me know if there is anything I can do to assist the TNSIA from a regulatory or legislative standpoint.

Paula A. Flowers, Esq.
Farmer & Luna, PLLC

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