The BUCA pre-pay editing 'advantage'? Largely a myth. BUCA carriers built their editing engines to protect their fully insured book — not yours. Independent TPAs are sitting on the single most powerful differentiator in the market — and most haven't deployed it yet.

$1.4 billion recovered. 878 investigations closed. And that was just the warm-up. On January 15, 2026, the DOL announced a wholesale shift of enforcement resources directly toward self-funded health plans, TPAs, and the fiduciaries who oversee them.

Your TPA's dashboard shows you what was paid. It doesn't show you whether it was paid correctly. Stephen Carrabba joins the PLANSPONSOR Roadmap 2026 Livestream Series to walk plan sponsors through the questions carriers would prefer they didn't ask.

The era of passive plan oversight is over. Schlichter's 4-suit December 2025 dump, the Supreme Court's Cunningham decision, the Sixth Circuit's Tiara Yachts ruling, and the CAA 2026 PBM reforms together create a perfect storm of fiduciary risk. Here's what every self-funded plan fiduciary must know.

99% accuracy claimed. 1.4% errors admitted. Millions missing. UnitedHealthcare recovered $922M for self-funded clients in 2022 — and kept up to 35% of those dollars. The Aetna/Optum 'dummy code' settlement. Cross-plan offsetting. Spread pricing. Here's what carrier self-reporting actually looks like.

Your TPA's contractual 'guarantees' of payment accuracy may be worth far less than the paper they're printed on. The Sixth Circuit's Tiara Yachts ruling, combined with EBSA's $1.4B in FY 2025 recoveries, tells a clear story: fiduciary duty cannot be satisfied by self-reported metrics from the same vendor processing your claims.

The voluntary benefits lawsuits weren't about accident insurance. They were about the process. The same procedural prudence framework is now being applied to healthcare benefits.

Every year, self-funded health plan fiduciaries are handed a legal contradiction. ERISA holds them personally liable for billions in plan assets. Yet the TPAs who actually pay those claims routinely deny access to the data required to validate that spending. A fiduciary cannot prudently oversee what it cannot see.

The January 2026 issue of The Self-Insurer makes one thing clear: 'fiduciary' is no longer a formality buried in plan documents — it's a market force reshaping vendor relationships, compressing margins, and raising expectations for transparency and performance.