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Establishing a self-funded plan

Jun 29, 2026 1 minute read
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Once a decision has been made to self-fund its health plan, there are several steps an employer should take, regardless of whether it is establishing a new plan or transitioning from a fully-insured plan.

  1. Appoint fiduciaries who will act in the best interest of the plan and its participants. 
  2. Secure stop-loss coverage. Stop-loss coverage is essential to protect the company’s (or, if applicable, the trust’s) assets against catastrophic claims.  
  3. Prepare a health plan document. 
  4. Contract with a TPA. When selecting a TPA, consider whether the vendor:
    • Accurate and timely processing of claims, including systems for detection of errors, duplicate charges, fraudulent charges, and a comprehensive auditing and recoupment process.
    • Access to a broad network of medical providers.
    • Quality and cost data that allows members to make informed choices.
    • Cost control programs, such as case management and disease management.
    • Compliance support, such as drafting and distribution of summary plan descriptions (SPDs) and summaries of benefits and coverage (SBCs).
    • Non-discrimination testing
  5. Consider fiduciary liability insurance to protect your assets in the event of error, breaches of federal law, or fraud on the part of your fiduciaries or administrative agents.