Last reviewed October 2026

What should an employer look at when choosing a TPA for a self-funded plan?

Short answer: Compare the services actually included, the network and PBM arrangements, data access, claims accuracy and service, stop-loss coordination, licensing, and all fees including indirect compensation, and document the comparison, because choosing the TPA is itself a fiduciary decision.

A TPA can be an independent administrator or a carrier providing administrative services only (ASO). Either way, the employer remains responsible for prudently selecting and monitoring it.

  • Scope: which services are included and which cost extra (COBRA, appeals and external review, Form 5500 support, RxDC data, gag clause attestation, stop-loss filings, HIPAA documents).
  • Network and pharmacy: which network is rented, provider disruption, and whether the PBM is required or can be carved out.
  • Data: written rights to de-identified claims data during and after the contract; federal law bars gag clauses that restrict it.
  • Money: all fees, network access and shared-savings fees, and the written compensation disclosure a covered service provider must give the plan fiduciary when it expects $1,000 or more.
  • Stop-loss: experience filing claims with the chosen carrier, and turnaround time.
  • Texas license status with TDI.

Ask for sample reports and references from employers of similar size.

Sources