Ultimate Health Plans Inc Final Order

FILED

MAR 23 2026

INSURANCE REGULATION

Docketed by: LLV

The Great Seal of the State of Florida, featuring a central shield with a landscape scene, surrounded by a circular border with the text "GREAT SEAL OF THE STATE OF FLORIDA" and "IN GOD WE TRUST".

Great Seal of the State of Florida

OFFICE OF INSURANCE REGULATION

MICHAEL YAWORSKY

COMMISSIONER

IN THE MATTER OF:

ULTIMATE HEALTH PLANS, INC.

Index: OIR 2026-26

CASE NO.: 402587-26-FO

FINAL ORDER

TO: ULTIMATE HEALTH PLANS, INC.

c/o Enrico Romeo

1244 Mariner Blvd.

Spring Hill, FL 34609

The STATE OF FLORIDA, OFFICE OF INSURANCE REGULATION ("Office"), being authorized and directed to administer and enforce the Florida Insurance Code, hereby enters this Final Order against ULTIMATE HEALTH PLANS, INC. ("UHP"), pursuant to section 641.23(2)(a), Florida Statutes.1

JURISDICTION

1. The Florida Insurance Code ("Code") grants the Office jurisdiction over the subject matter and the parties herein.

2. The Office has discretionary authority under section 641.23(2)(a) to issue this Final Order requiring compliance within thirty days from UHP.

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1 All statutory citations contained herein refer to Florida Statutes (2025), unless otherwise noted.

FINDINGS OF FACT

1. The Office licensed UHP as health maintenance organization (“HMO”) in the State of Florida by issuing Consent Order No. 124485-12-CO on March 29, 2012 (the “Licensing Consent Order”).

2. UHP maintains its principal place of business at 1244 Mariner Blvd., Spring Hill, FL 34609 as its address of record with the Office.

3. UHP’s membership consists of Sehat Partners, LLC and other members. Sehat Partners, LLC maintains a 58.75% membership interest, and the other members maintain the remaining 41.25% membership interest. Other than Sehat Partners, LLC, no other member holds a membership interest of more than 10%.

4. UHP’s management consists of Chief Executive Officer, Enrico Romeo; and President, Treasurer, and Interim Secretary, Medhat Allam Reheem. Arthur Diehl and Purna Bikkasani serve as UHP’s Directors.

5. As of December 31, 2025, UHP has 7,705 subscribers. These subscribers are enrolled in Medicare Advantage Plans, including Chronic Condition Special Needs Plan (“C-SNP”), Dual Eligible Special Needs Plan (“D-SNP”).

6. C-SNP enrolls special needs individuals with severe or disabling chronic conditions, defined in 42 C.F.R § 422.2.2

7. D-SNP enrolls individuals who are entitled to both Medicare and Medicaid due to their condition(s).3

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2 Centers for Medicare & Medicaid Services, Chronic Condition Special Needs Plans (C-SNPs), CMS.gov (March 9, 2026, 2:34PM), https://www.cms.gov/medicare/enrollment-renewal/special-needs-plans/chronic-conditions.

3 Centers for Medicare & Medicaid Services, Dual Eligible Special Needs Plans (D-SNPs), CMS.gov (March 9, 2026, 2:34PM), https://www.cms.gov/medicare/enrollment-renewal/special-needs-plans/dual-eligible

1. UHP entered into administrative service agreements with both Mirra Health Care, LLC, (“Mirra Health”) and Customer Service and Technology Solutions, LLC (“CSTS”).
2. Mirra Health and CSTS perform critical services on behalf of UHP such as enrollment, claims adjudication, and appeals.
3. The Office reviewed UHP’s contracts for administrative services with CSTS and Mirra Health.
4. None of the contracts the Office reviewed contained statutorily mandated language, allowing the Office to cancel the contracts upon issuance of an order.

CONCLUSIONS OF LAW

1. Section 641.23(2)(a) authorizes the Office to order an HMO to comply with the requirements in Part I of chapter 641 upon a finding that the HMO is not in compliance with Part I of Chapter 641.
2. Section 641.234(1) authorizes the Office to require HMOs to submit any administrative service agreements to the Office.
3. Section 641.234(3) requires administrative service agreements with HMOs to contain a provision mandating “that the contract shall be canceled upon issuance of an order by the Office of Insurance Regulation pursuant to this section.”

4. The Office has reviewed UHP’s contracts for administrative services with CSTS and Mirra Health and finds that UHP failed to include the language required by section 641.234(3).

5. Accordingly, the Office concludes that UHP's administrative service agreements with Mirra Health and CSTS violate section 641.234(3).

6. Based on the foregoing Findings of Fact and Conclusions of Law, the Office hereby issues the following FINAL ORDER:

• i. By the 30th day after the execution of this Order, all contracts for administrator services to be performed directly or indirectly on behalf of UHP must include the language required by section 641.234(3).
• ii. By the 30th day after the execution of this Order, UHP shall cease reliance on administrative service agreements, including administrative service agreements to which it does not have privity but from which it accrues benefits, that fail to include the language required pursuant to section 641.234(3).
• iii. On the 31st day after the execution of this Order, pursuant to section 641.234(1), UHP shall submit all administrative service agreements, including administrative service agreements to which it does not have privity but from which it accrues benefits, for the Office's review.

DONE and ORDERED this 23 day of March, 2026.

The seal of the Office of Insurance Regulation, State of Florida. It is a circular emblem with a gold border. The words "OFFICE OF INSURANCE REGULATION" are written in a circular border at the top, and "STATE OF FLORIDA" is at the bottom. In the center of the seal, there is a depiction of a figure standing on a pedestal, possibly a statue or a symbolic figure, surrounded by a wreath.

Seal of the Office of Insurance Regulation, State of Florida

MICHAEL YAWORSKY

Commissioner

Office of Insurance Regulation

NOTICE OF RIGHTS

Any party to these proceedings adversely affected by this Order is entitled to seek immediate appellate review of this Order pursuant to section 120.569(2)(n), Florida Statutes (2025), Rule 28-106.501, Florida Administrative Code, and Rule 9.110, Florida Rules of Appellate Procedure. Review proceedings must be instituted by filing a Petition or Notice of Appeal with the Agency Clerk at 200 East Gaines Street, Tallahassee, Florida 32399-4206, and a copy of the same and filing fee with the appropriate District Court of Appeal within thirty (30) days of the rendition of this Order. Mediation under section 120.573 is not available for this agency action.

--- CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order against Ultimate Health Plans, Inc. has been sent by U.S. Certified Mail this 23 day of March, 2026, to:

ULTIMATE HEALTH PLANS, INC

c/o Enrico Romeo

1244 Mariner Blvd.

Spring Hill, FL 34609

Stephanie Roman Caban

Florida Bar No.: 1030977

Assistant General Counsel

Office of Insurance Regulation

200 East Gaines Street

Tallahassee, Florida 32399-4206

Email: Stephanie.RomanCaban@flor.gov