
Oregon regulators have told ClearShare Health to hit pause on doing business in the state, accusing the group of running what amounts to unlicensed health insurance under the banner of a membership program. The Oregon Division of Financial Regulation (DFR) issued a cease-and-desist order that blocks ClearShare from marketing, selling or collecting payments for new or renewed memberships in Oregon. The move follows a DFR review that began in January 2026 and is aimed at keeping consumers from mistaking the memberships for Affordable Care Act-style plans that come with state and federal protections.
What regulators found
According to KPTV, DFR concluded that ClearShare never obtained a certificate of authority or a third-party administrator license required under the Oregon Insurance Code. Without that paperwork, the agency says, ClearShare’s cost-sharing memberships function as the business of insurance without the licenses the law demands. The review was launched after the division received multiple consumer complaints about how ClearShare was operating in the state.
How ClearShare's membership works
ClearShare bills itself as a “membership-based non-insurance community” and a 501(c)(3) that takes in monthly contributions from members and pools that money to pay eligible medical expenses, according to ClearShare. The program uses waiting periods and limits on sharing for pre-existing conditions.
State regulators say some membership tiers go further, excluding people with certain pre-existing conditions or anyone older than 65, according to KTVZ. That kind of screening can leave older or sicker Oregonians without the protections they would typically get under licensed health plans.
Order details and who it names
The cease-and-desist order does not stop with ClearShare itself. It also names affiliates Clearwater Benefits LLC, Clearwater Benefits Administrators LLC and Clearwater Benefits Holdings LLC, and it includes an order against Douglas Sherman, a co-founder of Clearwater Benefits, officials said. The decision forbids anyone involved from claiming that ClearShare memberships are exempt from DFR oversight, and it bars them from soliciting, collecting or receiving money from Oregon residents for new or renewed memberships, according to KPTV.
Existing members are not left completely in the lurch. Regulators are allowing the companies to keep administering and paying eligible medical expense submissions for memberships that were active as of April 14, so current members can continue to submit claims under their existing terms, per Z100 Portland.
A pattern of enforcement
This is not ClearShare’s first run-in with state insurance cops. In December 2025, Washington’s insurance commissioner fined ClearShare and related entities for selling unauthorized health coverage and ordered them to stop transacting in that state, according to the Washington Office of the Insurance Commissioner. That investigation found ClearShare sold hundreds of memberships in Washington and collected more than $500,000 from members, while denying or partially denying a notable share of the claims submitted.
How Oregon consumers can protect themselves
DFR is urging Oregonians to double-check that any health coverage outfit they are considering is properly licensed. The agency directs consumers to its online tools or to a health insurance advocate who can be reached at 888-877-4894 or [email protected] for help with questions or complaints, per DFR.
Consumers who are already enrolled with ClearShare are advised to pull out their membership paperwork and confirm what is still eligible for sharing under the company’s guidelines and the terms of the DFR order. Anyone facing unpaid medical bills or denied claims is urged to keep detailed records and consider filing a complaint with DFR for assistance.
Regulators say clamping down on unlicensed products like this is about protecting both individual consumers and the broader, licensed insurance market. DFR has signaled it will keep monitoring for similar setups and will pursue enforcement when companies operate outside Oregon law.









