Podcast

Undisclosed Fees and Costs: The Bad and The Ugly

There is no GOOD hidden fee in your self-funded healthcare plan.

Ask questions are you aware of the hidden fees with check box for yes or no and pen hovering over the yes checkboxWe’re all familiar with hidden fees or undisclosed costs. We see the “extra charges” once we’re ready to check out on Ticketmaster, VRBO or any major airline, to name a few. These charges are so common that they really aren’t “hidden” anymore. We know they are coming.

Unfortunately, such fees in self-funded healthcare plans aren’t as easy to spot – and they can add up to significant dollars for both the self-funded employer and plan beneficiaries. Read more to learn what you should watch for in your plan agreement.

Expected Fees

The fees that self-funded employers typically monitor are administrative fees. These fees may be based on a percentage of total paid claims, or they may be calculated by a formula outlined in a plan agreement. No matter how calculated, you know these fees are a cost of having a third-party administrator (TPA) oversee your health plan operations.

Undisclosed Fees and Costs

These fees are the ones you don’t see coming.  A large employer recently filed a lawsuit against its health plan administrator claiming that the TPA has, for over a decade, wrongfully charged millions of dollars in undisclosed fees.  Some of the claims made in the lawsuit could be summarized as follows:

  1. Lack of due diligence. While timely payment of claims is expected and desired, when claims are paid “almost immediately, with no follow-up inquiry” mistakes are often made. These may be duplicate payments or overpayments. Either way, the self-funded employer is incurring costs that are not expected or justified.
  2. Cross-plan offsetting. If a claim is overpaid to a provider using funds from one client, it is alleged that a major TPA “corrects” this by deducting the overpayment from its next payment to the provider. While the net effect to the provider is appropriate reimbursement for services rendered, that next payment reduction is allegedly done without regard to which employer gets the benefit of the lower payment. These dollars should be credited to the employer that was charged the original overpayment.
  3. Use of repricing companies. When a TPA receives claims from out-of-network providers, it often engages a repricing company to negotiate lower payments to the provider. This practice should be outlined in the plan agreement and there should be transparency as to the repricing company used. In this litigation, the employer claims the TPA owns the company collecting payments for negotiating settlement amounts – an undisclosed conflict of interest and possible double-dipping.

Ways to Avoid Hidden Fees and Excess Costs

The most important thing you can do to avoid hidden or undisclosed fees in your employee health benefit plan is to ensure that you understand exactly what is in your plan agreement. When it is time to review and renew a plan agreement, consider the following:

  • Fees may vary depending on the TPA and the type of policy.
  • The fees may be waived or reduced under certain circumstances.
  • Ask about all fees upfront, including any arrangements with companies affiliated with your TPA. Don’t be afraid to ask that all fees be disclosed and fully explained.
  • Get quotes from multiple plan administrators. This is the best way to make sure that you’re getting the best deal.
  • Monitor and evaluate all charges or “cost savings fees” by your TPA under any “shared” cost-savings arrangements.  Such so-called savings may prove unfounded.
  • Understand the surcharges and reinsurance fees that may be associated with the plan. These fees can add up, so it’s important to be aware of them before you choose a plan.
  • Have a comprehensive audit performed annually by an independent company that has no conflicts of interest with any TPAs or insurance brokers.

Healthcare Horizons’ comprehensive medical claims audits identify overpaid claims and uncover hidden fees.  In addition, we offer complimentary reviews of your third-party administrative services agreement audit rights language to ensure you aren’t restricted to a random sample audit. Let us help you uncover hidden fees and undisclosed costs before they hit your bottom line.


Healthcare Horizons is a leading expert in providing healthcare claims audit services, identifying overpaid or erroneous claims through our 100% Difference model and recovering millions of dollars for clients’ bottom lines while upholding the highest ethical standards. Since 1999, the Knoxville, Tennessee-based company has provided superior healthcare claims audits for some of the world’s largest self-insured employers. We have successfully identified and facilitated the recovery of millions of dollars of overpaid claims for our customers.

The Top Two Questions to Ask Your TPA

We talk a lot about WHY you should be getting external healthcare claims audits. (These statistics emphasize the importance.) So, in this article, we are going to assume you have made the excellent decision to have audits. Congratulations! But did you know that all audits aren’t created equal? Do not assume that your self-insured healthcare plan’s audit rights are covered by the TPAs standard language. These are the top two questions you need to ask your TPA to make sure you are not paying for a less-than-thorough audit.

1.    Do you allow for full 100% comprehensive auditing, without restricting the audit to random sample selection?

TPAs are entrusted by clients to manage the claims and payments of the plan, but their money is not at stake – yours is. Your company deserves the same protection a TPA would require for their own fully-funded plan.

There are two primary types of audits: random sample and comprehensive. Insist on comprehensive audits.

The typical outdated methodology for medical claims auditing is random sample selection. In this type of audit, auditors randomly select 200-300 claims out of millions of transactions. Auditors examine those claims for errors based on predetermined criteria and extrapolate the results to determine a claims error percentage of the entire data set. This approach historically has been considered standard practice when handling a large number of claims, but it carries a high margin of error that can work against the company in three ways.

  • If the auditor encounters an error on a randomly selected sample claim, it is virtually impossible to determine if the error is isolated or systemic in nature.
  • It is likely that significant one-off errors exist outside of the random sample selection.
  • It is often difficult to convince payers to issue settlements based on the results of a random-sample audit.

We are different because of our comprehensive auditing process. We review every healthcare claim and Healthcare Horizons leadership submits a specifically targeted selection of claims to review onsite with the carrier. Our approach yields much better results because we identify both isolated and systemic errors and assign actual dollar impact to those errors, making a much stronger case to the payer.

If you are settling for a random sample selection audit, you are throwing money away. Unfortunately, many TPAs only want to allow random sample selection audits. They know the likelihood of any error being found using this method is much smaller. When comprehensive audits look at every claim, data errors will be found. But finding mistakes is a GOOD THING – for you. Insist on comprehensive audits.

2.     Do you limit the number of audits that can be performed?

Service agreement audit language may contain many stipulations. A common restriction is on the number of audits conducted over a set length of time. Much like restricting audits to random sample selection, restricting audit frequency significantly limits the potential for errors to be discovered. Therefore, your ability to recover overpaid dollars is also greatly reduced.

Top Two Questions During Audit Review

Service agreements should not limit the number of times you can request healthcare claims audits. We recommend annual audits, not every other year as many TPAs enforce. One of the reasons that annual audits are so important is that claim recoveries are subject to time limits. It is common for the service agreement language to restrict claims recovery to two years or less. Here is the basic problem: when audits are not performed each year, claims may be too old to recover.

For example, in 2022 we can look back at the 2021 claims dataset for errors. If the audit is not performed until 2023, these 2021 claims will be too old to recover. If you are not having regular audits and a claim falls out of the timeline eligible for review, you will be out the dollars overpaid.

For our largest clients, we may audit quarterly, but annual reviews protect self-funded companies and their employees from overpayments and out-of-pocket expenses. In addition, our auditors are there to improve processes by providing suggestions and identifying inconsistencies, which will help eliminate overpayments and systemic errors.

The Top Two Questions Make the Difference

Now you know the top two questions to ask your TPA to ensure you are receiving the fullest scope of audit rights. Your next step is to work with someone that understands your rights, can execute a comprehensive audit, and return the most money to your bottom line.

In our 23 years of providing comprehensive healthcare claims audits, we have seen virtually every benefit setup, provider contract method, and claims administration policy that one would expect on claims audits of the world’s largest self-insured employers. Because of this experience, we quickly assess gaps in the healthcare audit rights in your service agreement. We offer a free audit rights assessment to make sure the audit language in your service agreement is not limiting your ability to recover funds. It is YOUR data and, more importantly, YOUR money. Don’t leave it on the table!


Healthcare Horizons is a leading expert in providing healthcare claims audit services, identifying overpaid or erroneous claims through its 100% Difference model, recovering millions of dollars for clients’ bottom lines with uncompromising ethics and accuracy. Since 1999, the Knoxville, Tennessee-based company has provided superior healthcare claims audits for some of the world’s largest self-insured employers. We have successfully identified and facilitated the recovery of millions of dollars of overpaid claims for employers.

Tax Day: Double-Check the Details

If you’re like us, before taxes are submitted you will double-check the details several times. It’s smart to give the return one more review to make sure nothing was missed. If it’s important to review your personal finances, isn’t it equally important to review your business’s financial health?

Audits Find Errors

In our business, we all too often see healthcare plans that never receive the benefit of another review. Self-insured employers trust third-party administrators to process and pay claims that are consistent with the plan details and are error-free. In many cases, there is no incentive for the TPA to identify and correct errors. Make sure your agreement allows for audits. It is your money!

Double-Check your Audit is Comprehensive

don't gamble double-check your audits
Photo by Conor Ogle

Does your healthcare service agreement allow for comprehensive audits to find errors and recover funds? Even when a random sample audit is conducted, the odds are against you that it will land on a claim filed in error. Additionally, there is no way to find and resolve systemic issues to prevent future claims paid in error.

That is why we are so passionate about comprehensive claims audits. We want our clients to have the peace of mind that comes with knowing that every claim has been reviewed and that every systemic issue has been corrected. Please contact us to discuss a claims audit for your plan.

*This blog was originally posted 4/18/2106 and has been updated.


Healthcare Horizons is a leading expert in providing healthcare claims audit services, identifying overpaid or erroneous claims through its 100% Difference model, recovering millions of dollars for clients’ bottom lines with uncompromising ethics and accuracy. Since 1999, the Knoxville, Tennessee-based company has provided superior healthcare claims audits for some of the world’s largest self-insured employers, involving all national and most regional payers. We have successfully identified and facilitated the recovery of millions of dollars of overpaid claims for employers.

The Biggest Mistake in Healthcare Agreement Negotiations

Each year, companies – and their employee benefits manager or health insurance broker – hold negotiations with third-party administrators (TPAs) to handle the details of self-funded healthcare plans. These agreements can directly impact a company’s bottom line.

Considering the rising cost of healthcare and incidences of significant overpayments of claims, including fraudulent or abusive claims, ensuring the plan addresses its fiduciary responsibilities is very important. If you are currently in the important “negotiations season,” be sure your self-funded healthcare plan is fully protected.

Did You Know?

You don’t have to accept the standard audit language in a proposed TPA agreement. It is an ERISA fiduciary responsibility of human resource managers or benefits consultants/brokers working on behalf of their plan to ensure that the language included in a services agreement is beneficial to everyone, but most importantly to the company.

The Most Common Mistake in Negotiations

Most TPAs will tell clients that they do in fact have audit rights within their agreements. However, in too many cases, the language is very restrictive and doesn’t really protect the company. Not negotiating for full audit rights is a HUGE mistake!

Full audit rights include these key components:

  • Comprehensive claims review, not just random sampling
  • Non-restrictive targeted sample size
  • Minimum of two-year period for recovery of overpayments
  • Fee structure based on recovery, not fixed

Random Sample vs. Comprehensive Audits

Random sample audits are usually listed as the allowed audit type the standard audit found in
most TPA agreements. Sometimes TPAs do not allow any type of audit. The biggest downside to random sample audits is that they, obviously, do not allow for a full review of all the data. When only a randomly selected portion of a data set is analyzed, it is nearly impossible to identify any patterns of abusive billing or systemic issues.

While benefits consultants claim they are performing audits and don’t need an external audit company, most of these audits only consist of

  • high dollar claims,
  • eligibility reviews, or
  • obvious fraudulent charges.

Here is one example of how a random sample audit works.

  • Auditors randomly select approximately 200-300 claims out of millions of transactions.
  • Auditors examine those claims for errors based on predetermined criteria.
  • Auditors extrapolate the results across the entire range of millions of claims to determine a claims error percentage of the entire population.
This approach carries a high margin of error that can work against the company. The fallout from the random sample approach is significant.
  1. If the auditor encounters an error on a randomly selected sample claim, it is virtually impossible to determine if the error is isolated or systemic in nature.
  2. It is likely that significant one-off errors exist outside of the random sample selection.
  3. It is often difficult to convince payers to issue settlements based on the results of a random-sample audit.

Random sample audits may leave undiscovered mistakes, and therefore money, on the table. This penalizes not only the company but the employees as well.

Conversely, a comprehensive audit starts with a review of the entire data set and an identification of known trouble areas. Audit companies with decades of experience can see red flags in data sets and start reviews at this point. Then, the comprehensive audit can pinpoint isolated and systemic errors in the audit process. Actual dollar amounts are assigned to these mistakes, making it very easy for payers to see where reimbursement is owed. As a result, employers can recover significantly more in overpayments and can correct root causes of the issues, which will prevent future claims from being paid in error.

Demand Comprehensive Audits Rights During Negotiations

There are numerous misconceptions about working with an outside auditing firm. The most common is that many TPAs believe working with a company like Healthcare Horizons will penalize them. At Healthcare Horizons, we work WITH a TPA to ensure errors are found and corrected. The TPA has the interest to see that their client is protected.

During the next negotiations cycle, HR departments, benefits consultants/brokers, and TPAs need to work together to demand accountability in healthcare claims and protect the financial interest of the client.

Use this checklist to make sure you have comprehensive audits rights in your TPA agreement. It’s YOUR money and your fiduciary responsibility to make sure that your medical plan is being administered appropriately.

negotiations checklist

Healthcare Horizons offers a free assessment of administrative service agreements to determine the proper inclusion of audit rights. Contact us so we can help you manage your fiduciary responsibility as it pertains to your company’s self-funded healthcare plan.


Healthcare Horizons is a leading expert in providing healthcare claims audit services, identifying overpaid or erroneous claims through its 100% Difference model, recovering millions of dollars for clients’ bottom lines with uncompromising ethics and accuracy. Since 1999, the Knoxville, Tennessee-based company has provided superior healthcare claims audits for some of the world’s largest self-insured employers, involving all national and most regional payers. We have successfully identified and facilitated the recovery of millions of dollars of overpaid claims for employers.