Oregon DFR Issues Cease-and-Desist Order Against Unlicensed Health Program

The Oregon Division of Financial Regulation (DFR) has issued a cease-and-desist order against ClearShare Health and its affiliates, citing their lack of proper licensing to conduct insurance business within the state. The DFR discovered that these entities were providing services without the crucial third-party administrator license, thus violating the Oregon Insurance Code.

The investigation began in January 2026, uncovering that ClearShare Health was operating a cost-sharing program described as "memberships." Participants contributed monthly to a fund aimed at covering medical expenses. The DFR determined this structure necessitated compliance with the Oregon Insurance Code.

Involved in this order are Clearwater Benefits LLC, Clearwater Benefits Administrators LLC, and Clearwater Benefits Holdings LLC. Douglas Sherman, co-founder of Clearwater Benefits LLC, was also named in the order. ClearShare Health's program includes various membership tiers that determine coverage for medical costs, generally excluding individuals with pre-existing conditions or those over 65 years old.

The issued order prohibits ClearShare Health and related entities from engaging in activities such as marketing, selling, or promoting memberships to Oregon residents and from collecting payments for these services. They're also barred from claiming that their memberships fall outside of DFR's regulatory oversight.

However, the order permits these companies to manage and process medical expense claims for current members, effective April 14, 2026, ensuring that existing customers continue to receive their contracted services. This action reflects DFR's commitment to regulating unlicensed entities posing as health insurance providers or engaging in similar financial agreements.

The investigation was prompted by consumer complaints, revealing unlicensed practices potentially impacting the legitimate insurance risk pool. Earlier, in January, the DFR had issued warnings to consumers about increasing fraudulent activities within the evolving health insurance landscape.

For consumers, the DFR advises conducting thorough research on coverage plans to ensure they meet required standards and adhere to the Affordable Care Act. The division offers resources on its website for checking licenses, addressing queries, and lodging complaints. Consumers can also connect through a toll-free number or email for further assistance from a health insurance advocate.