TPA & stop-loss fees
Your broker isn't the only place compensation hides.
TPA administration fees and stop-loss commissions can carry the same embedded, hard-to-see costs as broker pay. Today, most of it doesn't even reach a public filing.
The gap self-funding doesn't close
Self-funded doesn't mean fee transparent by default.
Self-funding removes the insurer's built-in risk margin, but it doesn't automatically make every downstream vendor transparent. The plan sponsor still has to ask the right questions.
Spread pricing on out-of-network repricing›
The TPA or its repricer keeps a cut of the gap between billed charges and what’s actually paid.
Retained PBM overrides›
Overrides passed through the TPA that may never show up as a line item you can see or negotiate.
Percentage-of-savings fees›
Fees stacked on top of the PEPM admin fee, often framed as shared savings rather than compensation.
Stop-loss commission›
Typically 1–15% of stop-loss premium — and it can go undisclosed even on a plan sold as “fee-only.”
Why you can't see it here (yet)
A structural gap in the data — not a claim about any one plan.
Unbrokered's broker benchmarks are built from Form 5500 Schedule A (insurance commissions) and Schedule C (service-provider fees) — public data the Department of Labor already requires.
Most self-funded plans are legally “unfunded” (claims paid from the employer's general assets, not a trust), and Schedule A/C reporting is largely triggered only when a plan is trust-funded. That means for most self-funded employers, TPA fees and stop-loss commissions simply never appear on a public Form 5500 filing — not because anyone's hiding anything from the DOL, just because the filing requirement doesn't reach that far for most plans.
What's changing
New disclosure duties are coming — to the plan sponsor, not the public file.
Enacted: CAA 2026
The Consolidated Appropriations Act of 2026 (enacted February 3, 2026) broadened ERISA's covered-service-provider definition to include TPAs, PBMs, stop-loss insurance, and other listed health-plan services. The amendment did not state a delayed effective date; confirm how it applies to each new, extended, or renewed arrangement with counsel.
Proposed: DOL advance disclosure
Separately, the Department of Labor proposed a rule on January 30, 2026 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure — that would require PBMs, and their affiliated brokerage and consulting providers, to disclose their compensation to the fiduciaries of self-insured plans. This is a proposed rule, not final — the comment period closed March 31, 2026, and the timeline could change, slip, or not be adopted at all. Treat it as regulatory direction of travel, not a locked-in date.
Either way, this new disclosure goes directly to the plan sponsor — it's not a new public filing. It won't automatically show up in a dataset like this one the way broker commissions do.
Start with the disclosure you already have.
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