Short answer: Generally yes. Texas requires administrators to hold a TDI certificate of authority under Insurance Code Chapter 4151 unless an exemption applies, and TDI will not decide whether an exemption applies. License status can be checked through the Sircon business search.
Even though ERISA preempts state insurance mandates for the self-funded plan itself, Texas still licenses the administrator. TDI’s TPA page explains that applications are filed through Sircon (Form FIN489), licenses do not expire, and a TPA must file an annual report by June 30 with a $200 filing fee, including evidence of fidelity bond coverage and financial statements. A licensed insurer or HMO acting as a TPA notifies TDI instead.
TDI states that it cannot give legal advice or determine whether a particular entity is exempt under Insurance Code Section 4151.002.
Before recommending a TPA, look it up with the Sircon “Search for a Business” tool. TDI also notes that PBMs licensed as TPAs must file an annual report under Insurance Code Section 1369.502 on rebates, fees and other payments.