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Oregon regulators said Monday they have moved to ban ClearShare Health from the state, alleging the “health share” is in fact health insurance—and that it has been offering such insurance here without a license.
The move comes after Washington state took a similar enforcement action against the organization in June 2025. As WW reported earlier this month (“Share My Burdens,” April 8, 2026), Washington insurance regulators have been far more aggressive than their counterparts in Oregon when it comes to scrutinizing alternative-to-health insurance business models.
Health care sharing arrangements often tout cheaper prices and a community rooted in common values, while asserting—debatably, some would say—that they are not in fact insurance and thus not subject to insurance law. They make this point for several reasons, including that even as they say they pay eligible health claims, they don’t want to have a legal obligation to do so. (They tend to be of particular appeal when health premiums spike.)
Oregon’s announcement of enforcement action against a health sharing arrangement, the first such action by state regulators since 2021, suggests the insurance commissioner may now be looking more aggressively into the business model.
“This action is part of [the Oregon Division of Financial Regulation’s] ongoing efforts to pursue entities offering health insurance or marketing products that function as health insurance but are not properly licensed,” the agency said in a news release. It added that it began looking into ClearShare after receiving “multiple consumer complaints.”
A Missouri nonprofit founded in 2022, ClearShare Health, which is tied to a previously existing Texas company called Clearwater Benefits, sells medical plans in Oregon and elsewhere. (There are other entities in the mix, including a Delaware holding company.)
Clearwater describes itself as a faith- and “membership-based community of individuals established for the purpose of sharing eligible health care expenses.” It also says it is “not insurance.”
It is this claim that Oregon regulators say they regard dimly. DFR said it began investigating ClearShare and its affiliates in January 2026 and found that, despite their claims not to be insurance, they have been functionally operating “as a business of insurance in Oregon.”
To be sure, the Oregon membership of ClearShare does not appear to be substantial. The state says that as of March 29, there were 370 Oregonians enrolled as ClearShare members. And though ClearShare has grown dramatically in recent years, the nonprofit lists revenue of only about $8 million in its latest tax filings. (In contrast, Zion Health, another health care sharing arrangement operating in Oregon, most recently reported overall revenue of about $90 million.)
Still, the move by Oregon regulators may put other health care sharing arrangements on notice. As part of this news release, the state warned consumers to be wary of health insurance options that are unlicensed or claim to comply with the Affordable Care Act when they do not.
The state order bars ClearShare Health and its affiliates from marketing or selling memberships to Oregon residents, taking fees for or renewing existing ClearShare Health memberships, or representing that its memberships are not subject to Oregon insurance regulation.
Still, the state says these entities may 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 may continue to have their medical expense submissions considered under their existing memberships.
ClearShare did not respond to a request for comment.
