State orders ClearShare to cease and desist insurance operations in Oregon; warns consumers on non-ACA plans

The Oregon Division of Financial Regulation (DFR) has issued a cease-and-desist order to ClearShare Health and its affiliates after determining that the entities have been operating a program that, based on DFR’s investigation, functions as a business of insurance in Oregon without first obtaining a certificate of authority. The order also alleges they were providing services without first obtaining a third-party administrator license, conduct DFR found to violate the Oregon Insurance Code.

ClearShare Health’s affiliates include Clearwater Benefits LLC, Clearwater Benefits Administrators LLC, and Clearwater Benefits Holdings LLC. The division also issued an order against Douglas Sherman, the co-founder of Clearwater Benefits LLC.

Under ClearShare’s cost-sharing program, which it refers to as “memberships,” consumers pay a monthly amount into a pool of money that is used to pay out members’ medical costs. According to information reviewed by DFR, which started its investigation in January 2026, ClearShare offers various tier levels consumers can choose that determine what medical expenses may be covered. People with pre-existing conditions or who are older than age 65 typically cannot participate in ClearShare’s program.

The order bars ClearShare Health and its affiliates from transacting insurance in Oregon, including but not limited to:

• Marketing, offering, or selling ClearShare Health memberships to Oregon residents
• Soliciting, collecting, or receiving any consideration, contribution, fee, or payment from Oregon residents for new ClearShare Health memberships or renewals of existing ClearShare Health memberships
• Representing that ClearShare Health memberships are not subject to regulation and oversight by DFR

The order allows these entities to continue to administer and pay medical expense submissions arising from ClearShare Health memberships that were in effect as of April 14, 2026, so that affected Oregon consumers can continue to have their medical expense submissions considered under their existing memberships.

This action is part of DFR’s ongoing efforts to pursue entities offering health insurance or marketing products that function as health insurance but are not properly licensed. DFR verifies that insurance companies are solvent (can pay their claims, make good on promises, etc.) and comply with Oregon law. ClearShare came under review after receiving multiple consumer complaints.

Consumers are often faced with health insurance choices, some of which may not be licensed by the state, or that claim to be in compliance with Affordable Care Act (ACA) plans when in fact they do not offer ACA-level coverage. These unlicensed activities also weaken the licensed, commercial risk pool by removing members from that pool. DFR has previously warned consumers that the ever-changing dynamics of the health insurance market this year has caused a rise in fraudulent activity with a press release in January.

DFR reminds consumers as they shop for health insurance to research each plan to make sure it provides the coverages you need, or will need, and that plans are in full compliance with the ACA. DFR’s website has tools to help you check a license, answer questions you may have, and file a complaint. If you need to talk with a health insurance advocate, you can call 888-877-4894 (toll-free) or email dfr.insurancehelp@dcbs.oregon.gov.

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About Oregon DFR: The Division of Financial Regulation protects consumers and regulates insurance, depository institutions, trust companies, securities, and consumer financial products and services. The division is part of the Department of Consumer and Business Services, Oregon’s largest consumer protection and business regulatory agency. Visit dfr.oregon.gov and dcbs.oregon.gov.