PART 2: IF YOU CANNOT ACCESS YOUR DATA, YOU CANNOT MANAGE YOUR PLAN
One of the biggest advantages of self-funding is access to information. However, this is not always the case.
VP of Employee Benefits · BHC Insurance · Independent Benefits Consultant
One of the biggest advantages of self-funding is access to information.
However, this is not always the case.
Many employers assume that self-funding guarantees timely, complete, and usable data. In practice, this expectation is not always met.
Some employers receive detailed claims information, utilization reporting, pharmacy data, high-cost claimant insights, and actionable recommendations.
Others receive only a monthly spreadsheet with totals and minimal context.
These levels of reporting are not equivalent.
Data should enable plan sponsors to identify cost drivers, care locations, risk factors, vendor performance, and potential opportunities.
It should also address practical questions such as:
Why did claims increase?
Are employees using the emergency room for care that could have been handled elsewhere?
Are specialty medications being administered in unnecessarily expensive settings?
Are members receiving preventive care?
Are chronic conditions being identified early?
Are cost-containment programs actually reducing the plan’s net cost?
A report that only states total spending is insufficient. By the time this information is available, the funds have already been spent.
The TPA should provide reliable data, interpret its significance, and ensure access for employers and their authorized advisors. Employers should also know who owns the data, how quickly it can be accessed, whether additional fees apply, and if information can be shared with external analytics or clinical partners.
Restrictions around data often become restrictions around strategy.
Without usable data, employers must make renewal decisions with incomplete information. They cannot effectively evaluate vendors, challenge recommendations, identify emerging risks, or measure plan improvement. manage healthcare more intelligently.
However, assuming risk without access to information does not provide control.
It is simply exposure.
In Part 3, I will address another major issue: whether the TPA can effectively integrate with the other partners supporting the health plan.
#SelfFunded #HealthcareData #EmployeeBenefits #TPA #PlanManagement #HealthcareTransparency #EmployerBenefitsIQ
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Sources & Further Reading
- Consolidated Appropriations Act, 2023 — Claims Data Access Requirements — Statutory basis for employer rights to access claims data from TPAs and carriers — the legal foundation for data ownership.
- DOL: Gag Clause Prohibition and Data Access Rights — DOL guidance on the CAA gag clause prohibition and employer rights to receive claims data from health plan vendors.
- PBGH: Claims Data Access and Employer Plan Management — Employer coalition guidance on what data employers should demand, how to use it, and what contractual provisions protect data rights.
- Health Affairs: Data Transparency and Employer Health Plan Performance — Research on the relationship between employer access to claims data and health plan cost management outcomes.
- Self-Insurance Institute of America (SIIA): Data Rights in Self-Funded Plans — Industry guidance on data ownership provisions in TPA contracts and the employer's right to claims-level data.
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About the Author
Corry Hull, REBC®, CSFS®
VP of Employee Benefits · BHC Insurance
Corry Hull, REBC® CSFS®, is VP of Employee Benefits at BHC Insurance and the founder of Employer Benefits IQ (www.employerbenefitsiq.com). He is a Certified Health Rosetta Advisor — one of fewer than 200 nationwide — and a multi-year presenter at United Benefit Advisors (UBA) national conferences. He specializes in self-funded health plan design, PBM contract strategy, stop-loss structuring, group medical captives, and ACA/ERISA compliance for mid-market employers. His work has been recognized by Health Rosetta (Rosie Award, 2026), UBA (Producer Peak Performer, 2025–2024), and BHC Insurance (Producer of the Year, 2021–2025). His employer-education content has been referenced in BenefitsPro and cited within the Health Rosetta advisor community. All consulting and brokerage compensation is fully disclosed.