William O. Williams II

T 317.237.3815
F 317.237.3900
201 North Illinois Street
Suite 1900
Indianapolis, Indiana 46204-4236

Bill is a member of Frost Brown Todd LLC’s Insurance Industry group, focusing his practice in the areas of Health and Insurance Regulation. He is an AV rated attorney by Martindale-Hubbell and a member of the Federation of Regulatory Counsel (FORC) and the American Health Lawyers’ Association (AHLA). Bill brings over 22 years of experience as in-house counsel representing hundreds of licensed life and health entities in administrative and regulatory matters before all state and federal insurance and health agencies. He also has significant experience managing major functions of an in-house law department, including building and maintaining systems to monitor change in law that impact insurance companies, their products and operations, systems of control over marketing and advertising materials, compliance programs to oversee sales operations, including employed or captive agents as well as independently contracted brokers, conducting multi-state regulatory research on all issues affecting insurance companies, and maintaining repositories of legal work product, research and contracts.

Representative Matters

Bill has significant subject matter expertise in the following areas:           

  • Insurance, HMO and other managed care entity licensing, organization and operations.
  • Life and health product development, pricing and underwriting.
    • Individual, small employer and large employer group fully insured health insurance and specialty products (vision, dental, term life, disability income, etc.).
    • Small and large group self-funded, stop loss, and administrative services only products.
    • Association group and trust related insurance arrangements, products, and operations.
    • Whole and term life insurance and annuity products, including accelerated death benefits to pay for home health and long-term care.
  • Risk pooling, rating, reinsurance and related financial requirements.
  • Claims adjudication, customer service and other insurance administration operations.
  • Clinical, utilization review, medical management and appeals activities.
  • Healthcare practitioner, provider, lab, and pharmacy network development, adequacy and accessibility requirements.
  • Regulatory filing and approval requirements for licenses, products, and all insurance and operational activities.
  • Insurance company holding systems, domestic and foreign.
  • International medical and travel insurance, covering inpatriates and expatriates, including surplus lines.
  • Risk-based capital, reserving, and other financial obligations.
  • Financial and market conduct exams, desk audits, and complaint investigations.
  • Administrative hearings and enforcement actions and appeals before state and federal agencies and courts.
  • Protection of confidential, proprietary, trade secrets in regulatory and other filings.
  • High-risk pools and other reinsurance/risk-sharing arrangements.
  • HIPAA and GLB privacy and security matters.
  • ACA requirements, including:
    • Insurance market reforms – guaranteed availability and guaranteed renewability.
    • Coverage of preventive care with no cost-sharing, including women’s contraceptives.
    • Coverage of dependents up to age 26.
    • Rate review, medical loss ratio (MLR), single risk pool, and 3 R’s (risk adjustment, risk corridors and reinsurance).
    • Prohibition on discrimination in eligibility and premiums based on health status-related factors.
    • Coverage of essential health benefits (EHBs) and metal level plans (bronze, silver, gold and platinum).
    • Exchange requirements, including qualified health plan certification, participation agreements and subsidies (advanced premium tax credit and cost-sharing reduction).
    • Section 1557 non-discrimination requirements. Individual and employer mandates and associated taxes.
    • Excepted benefits – hospital and other fixed indemnity and specified disease and illness plans.
    • Short term-limited duration insurance.
  • Insurance producers, agents and brokers.
    • Commissions and other forms of compensation. Lead generation arrangements.
    • Advanced payment of commissions, including security agreements and perfection of secured interests.
    • Captive agents and independent broker arrangements.
  • Sales, marketing and advertising of insurance brands and products.
    • Establishing systems of control over advertising for market conduct compliance.
    • Traditional brick and mortar sales operations and virtual presence web-based eAgencies.
    • Internal and external distribution channels and lead generation deals.
    • Brand and product management, including intellectual property

Memberships & Affiliations

  • American Health Lawyers Association, Member
  • Federation of Regulatory Counsel, Member

Civic & Charitable Organizations

  • Midwest Academy of Indiana, Trustee
  • Indiana Repertory Theatre, Director
  • Housing Corporation of Lambda Iota Chapter of the Fraternity of Phi Gamma Delta at Purdue University, Director

Non-FBT Publications and Events

Presenter: “Regulatory Monitoring Across the Multiple Jurisdictions in Which You Operate” – Corporate Counsel Exchange, May 15-17, 2011, Marriott Sawgrass, Ponte Vedra, Florida

Presenter: “The Affordable Care Act’s Insurance Market Reforms – Where have we been and where are we going?” – Indianapolis Bar Association’s Health Care Section, November 29, 2012, Indianapolis, Indiana

Presenter: “Enforcement of the Affordable Care Act’s Insurance Reforms – Who will come knocking on your door?” – ABA-TIPS Mid-Winter Symposium on Insurance & Employee Benefits, January 18, 2013, W Hotel, Fort Lauderdale, Florida

Other Contact Info


Renee Wake
T 317.237.3896