Third Party Administration of COBRA in Tennessee

[Guest stan]

HELP!! I have been told by the Tennessee Department of Commerce and Insurance that a third party administrator may not contract with Tennessee employers to provide COBRA continuation administrative services unless the tpa is also an insurance company or has a contract with the insurance company to provide the administration (not with the individual employers). Does anyone know if this is correct? If so, Tennessee seems to be the only state that prohibits tpa administration of continuation coverage (without the insurance company relationship).