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Self-funded health plans: roles, obligations and providers

In a self-funded health plan, the employer pays employees' covered medical claims from its own funds instead of buying a fully insured policy. Employers commonly hire a third-party administrator to run the plan and buy stop-loss insurance to limit large losses, but the plan's obligations remain the employer's.

An employer-funded health plan, usually run by a third-party administrator and backed by stop-loss insurance.

Who does what in a self-funded plan

Self-funded plans sponsored by private-sector employers are generally governed by federal law, chiefly ERISA, rather than state health insurance law. Stop-loss insurance bought by the employer is insurance, so states can regulate it. Government and church plans follow different rules. Each party's role should be written into its contract.

PartyTypical roleWhat stays with the employer
Employer (plan sponsor)Funds claims, sets plan terms, oversees the planBenefit obligations and fiduciary duties
Third-party administratorProcesses claims and eligibility, arranges network access, produces reportingResponsibility for the plan and for monitoring the TPA
Stop-loss carrierReimburses the employer above attachment pointsPaying members’ claims when they are due
Benefits counsel and consultantsPlan documents, compliance support, vendor selectionFinal decisions

The usual starting points are a TPA that administers your type of plan, a close read of stop-loss attachment points and exclusions, and benefits counsel to prepare or check the plan documents.

Benefits and limitations

Potential benefits

  • The employer pays actual claims, administration and any stop-loss premium, rather than a fully insured premium that includes the carrier's margin and risk charge.
  • Direct access to the plan's own claims data.
  • More room to design benefits, networks and programs, within the federal rules that apply to the plan.
  • Better-than-expected claims years benefit the employer.

Key considerations and limitations

  • The employer carries claims volatility; stop-loss limits it but reimburses the employer, not plan members.
  • For private-sector plans, plan-sponsor and fiduciary duties under ERISA, and applicable federal reporting and coverage rules, stay with the employer.
  • Cash flow is less predictable than a fixed monthly premium.
  • Results in small groups can be dominated by a few large claims.

Is this relevant to me?

When it may be worth exploring

  • Your workforce is large enough for claims experience to be a credible signal.
  • You want plan-design flexibility and your own claims data.
  • You will resource administration, compliance and plan governance properly.

When it may not fit

  • A handful of large claims would dominate a year's results.
  • Budget certainty matters more than potential savings.
  • There is no appetite for plan administration and compliance responsibility.

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