How does self-funded health insurance work? Self-insured medical plans, explained.

The short answer

Self-funded health insurance is a health plan where the employer pays employees' medical claims from its own money instead of buying a fully insured policy. A third-party administrator processes the claims, a pharmacy benefit manager runs the drug benefit, and stop-loss insurance reimburses the employer when claims pass set limits.

What is self-funded health insurance?

Self-funded health insurance, also called a self-insured medical plan, is a group health plan where the employer pays its employees’ medical and pharmacy claims instead of paying a fixed premium to an insurance company. The employer takes on the claims risk that a carrier would carry in a fully insured plan.

“Self-funded health insurance” is a slight misnomer. The plan itself is not an insurance policy. It is an employee benefit plan the employer sponsors, governed by a written plan document. The only insurance in a typical self-funded setup is stop-loss, which protects the employer, not the employees.

Self-funding is the most common way covered workers in the U.S. get employer coverage. In the KFF 2025 Employer Health Benefits Survey, 67% of covered workers were in self-funded plans, including 80% at firms with 200 or more workers and 27% at firms with 10 to 199 workers.

Fully insuredSelf-funded
Who carries claims riskThe insurance carrierThe employer, above which stop-loss reimburses
What the employer paysA fixed monthly premiumActual claims, plus fixed costs for administration and stop-loss
Main regulatorState insurance law and federal lawFederal law (ERISA, the Internal Revenue Code, the ACA, HIPAA)
State benefit mandates and premium taxesApplyGenerally do not apply to the plan
Plan designChosen from the carrier’s optionsWritten by the employer, within federal rules
Claims dataOften summary reportsThe plan’s own claims-level data
Unused claims moneyStays with the carrierStays with the employer

For a full side-by-side, see self-funded vs. fully insured.

How does the money flow?

In a self-funded plan, money moves through four pieces: the claims fund, the TPA, the PBM and stop-loss. The employer and employees fund the plan, the vendors pay claims from it, and stop-loss refills it when claims run high.

  1. Funding. The employer budgets an expected claims amount for the year, usually set with help from an underwriter or actuary, and collects employee contributions through payroll. Many employers deposit money into a dedicated claims account each month or each week.
  2. Claims are incurred. An employee sees a doctor or fills a prescription. The provider bills the plan, through the TPA for medical claims and through the PBM for prescriptions.
  3. Claims are paid. The TPA reprices the medical claim to the network rate (or another pricing method), checks it against the plan document, and pays it from the employer’s claims account. The PBM pays pharmacies and bills the plan for drug claims, usually weekly or every two weeks.
  4. Fixed costs are paid. The employer pays the TPA’s administrative fee, any network access fee, the PBM’s fees, and the stop-loss premium, usually per employee per month.
  5. Stop-loss reimburses. When one person’s claims pass the specific deductible, or the whole group’s claims pass the aggregate attachment point, the stop-loss carrier reimburses the plan for the excess.

The result is a cost that moves with actual claims. In a good year, the money not spent on claims stays with the employer. In a bad year, the employer pays more, up to the limits stop-loss sets. Monthly cash needs also swing, because claims do not arrive evenly. Some employers choose a level-funded plan instead, which spreads the expected cost into a fixed monthly payment.

Which vendors does a self-funded plan use?

A self-funded employer hires vendors to do the work a carrier does in a fully insured plan. Each one is a separate contract, which means each can be chosen, measured and replaced on its own.

VendorWhat it does
Third-party administrator (TPA)Processes and pays claims, handles eligibility and member service, issues ID cards and reports, and often coordinates stop-loss filings
Provider networkGives access to discounted rates with doctors and hospitals. It may be rented through the TPA or come from a carrier
Pharmacy benefit manager (PBM)Runs the drug benefit: formulary, pharmacy network, drug pricing and rebates
Stop-loss carrierInsures the employer against large individual claims and high total claims
Underwriter or actuarySets expected claims, funding levels and stop-loss attachment points
Add-on programsOptional programs such as care navigation, direct primary care, centers of excellence or condition management
ERISA counsel and compliance supportDrafts the plan document and SPD and helps with filings

Insurance carriers also sell self-funded administration, called administrative services only (ASO). Under an ASO arrangement the carrier acts as the TPA and supplies its network, but the employer still pays the claims. Independent TPAs offer the same administrative role and can pair it with a rented network, reference-based pricing or direct contracts with providers.

What does the employer have to do?

A self-funded plan sponsor takes on legal duties a carrier would otherwise handle. Most private employers’ self-funded plans are governed by ERISA, and the employer, or a committee it names, is the plan’s fiduciary for the decisions it makes about the plan.

RequirementWhat it means for a self-funded plan
Written plan documentERISA requires every plan to be established and maintained under a written instrument that names the plan’s fiduciaries. In a self-funded plan, the employer’s plan document defines what is covered, since there is no carrier certificate to rely on
Summary plan description (SPD)A plain-language summary of the plan given to participants. See summary plan descriptions
Form 5500The annual return filed with the DOL, due the last day of the 7th month after the plan year ends, with a 2½ month extension available on Form 5558. See Form 5500 deadlines
PCORI feeThe plan sponsor pays it directly on IRS Form 720 by July 31 of the following year. For plan years ending on or after October 1, 2025 and before October 1, 2026, it is $3.84 per covered life
HIPAA privacy and securityThe plan is a covered entity. The employer needs plan document language and internal safeguards before it handles employees’ health information for plan purposes, and the plan must give a notice of privacy practices
Section 105(h) nondiscriminationA self-insured medical plan cannot favor highly compensated individuals in eligibility or benefits. If it does, the excess reimbursements to those individuals become taxable income to them
COBRAPrivate employers with 20 or more employees on more than half their typical business days in the prior year must offer continuation coverage, and can charge up to 102% of the plan’s cost
ACA and other federal rulesThe plan must meet the ACA’s coverage rules, such as the out-of-pocket limit and preventive care, plus mental health parity, ACA employer reporting, the yearly gag clause attestation and the prescription drug (RxDC) report

A few points apply only to some plans. Welfare plans with fewer than 100 participants that pay benefits only from the employer’s general assets, insurance, or both are generally exempt from filing Form 5500. A self-funded plan that holds money in a trust has to file at any size. Governmental and church plans are generally outside ERISA and follow different rules, which ERISA vs. non-ERISA plans covers.

ERISA also generally keeps states from treating a private employer’s self-funded plan as an insurer. That is why state benefit mandates and state premium taxes on insured policies generally do not reach the plan, and why a multi-state employer can run one plan design across states.

What data does the plan own?

A self-funded plan owns its claims data. Every claim the TPA and PBM pay is a record of what the plan bought, from which provider, at what price. That is the raw material for managing cost.

With claims-level data, an employer can see:

  • Where the money goes, by provider, facility, diagnosis and drug, including how much a few high-cost members drive total spend.
  • What the plan actually paid, compared with billed charges and with Medicare rates for the same services.
  • How vendors perform, such as the PBM’s real pricing against its contract guarantees, or the TPA’s accuracy on claims it paid.
  • What stop-loss underwriters will see, so the employer goes into renewal knowing the same facts the carrier does.

The Consolidated Appropriations Act, 2021 backs this up. Contracts between group health plans and their TPAs, networks and other service providers cannot block the plan from getting its own de-identified claims data, and plans attest to that every year by December 31. The data still has to be handled under HIPAA, and the employer should get it from vendors under a business associate agreement.

Two Ethos Benefits clients show what this looks like in practice. Kalos Services, a 400-employee HVAC and trades company, moved from a fully insured plan to self-funding in 2022. Hendry Marine, a shipyard of about 300 employees, has been self-funded with reference-based pricing since 2017.

Which claims does stop-loss cover?

Stop-loss is what keeps a bad claims year from becoming a crisis, and the contract type decides which claims it actually covers. A contract is named by two numbers: the months in which a claim must be incurred, and the months in which it must be paid.

ContractWhat it coversWhen it is used
12/12Claims incurred and paid within the 12-month policy periodOften a mature plan staying with the same carrier
12/15Claims incurred in the 12-month policy period and paid within 15 months, a 3-month run-outWhen the employer wants protection for claims paid after the year ends
15/12Claims incurred in the 3 months before the policy plus the 12-month period, and paid during the policy periodA short run-in, common in a plan’s first self-funded year
24/12Claims incurred in the 12 months before the policy plus the 12-month period, and paid during the policy period, a 12-month run-inMoving from one stop-loss carrier to another
PaidClaims paid during the policy period, regardless of when they were incurredUsually after the first year with a carrier

A 24/12 contract is a run-in contract. It picks up claims that were incurred under the prior contract but are still being paid, so they are not stranded when the employer changes carriers. It does not reach back 24 months before the policy starts.

Two other terms decide how much protection a contract really gives:

  • Lasering. The carrier sets a higher specific deductible for one person with known high costs, or excludes that person. The employer pays that member’s claims up to the lasered amount.
  • Terminal liability. An option that adds run-out coverage if the plan ends or moves to fully insured coverage, so claims incurred before termination but paid afterward are still protected.

Specific stop-loss covers one person’s claims above a per-person deductible. Aggregate stop-loss covers the group’s total claims above an attachment point set from expected claims. Some states set minimums for both, based on the NAIC Stop Loss Insurance Model Act’s $20,000 floor for specific attachment points. For how attachment points, pricing and contract gaps work in detail, see how stop-loss insurance works, and for aggregate coverage specifically, aggregate stop-loss. Ethos reviews, places and audits stop-loss contracts through its stop-loss service.

Who does self-funding fit?

Self-funding fits an employer that can absorb swings in monthly claims cost, wants control over plan design and vendors, and will use its own data. Group size matters less than it used to, but financial capacity and appetite for active management still decide whether it works.

Self-funding tends to fitSelf-funding tends not to fit
Cash reserves or credit to cover a high-claims month, and the stop-loss deductible on several large claimants in one yearLittle cash cushion, or a need for the same health cost every month
A workforce large and stable enough that claims are reasonably predictableA very small or fast-changing group, where one or two large claims swing the whole year
Leadership willing to review claims data, vendor contracts and renewals each yearNo one with the time or support to manage vendors and compliance
Employees in several states, where one plan design is easier than several insured plansAn expected sale, merger or major workforce change in the near term
A long-term view, judging results over several yearsA goal of cutting cost in the first year, with no tolerance for a bad one

Employers that are not ready to self-fund fully have other options. Level-funded plans put a small self-funded layer under a fixed monthly payment, and they are common among smaller groups: KFF’s 2025 survey put 37% of covered workers at firms with 10 to 199 workers in level-funded plans. Some mid-sized employers join a stop-loss captive or a self-funded healthcare trust to share part of the risk with other employers.

Self-funding has real risks: uneven cash flow, the chance of several large claims in one year, lasers at renewal, run-out claims if the plan ends, and more legal work for the employer. It also has real advantages, from lower fixed costs to control over vendors and data. For an honest weighing of both, see self-funded health insurance pros and cons.

From the Ethos Benefits team

Like, fundamentally, if this is going to work for the plan at the end of the year, it's because it worked for the employees first.

Donovan RyckisBringing Fiduciary Strategy to Employer Healthcare | Benefits Advisor to Large Employers | Founder & CEO, Ethos BenefitsOn The Business of Benefits, Episode 84LinkedIn

Questions employers ask about this.

Is self-funded the same as self-insured?

Yes. Self-funded and self-insured describe the same arrangement, where the employer pays its plan's claims instead of paying a premium to an insurer that takes the risk. Most self-funded employers still buy stop-loss insurance to cap large claims. The two terms are used interchangeably in plan documents and federal guidance.

What does self-funded mean on an insurance card?

It means the employer's plan pays the claims, not the insurance company named on the card. In a self-funded plan, that company usually acts as the administrator, processing claims and providing the network. The label matters because state insurance law generally does not apply to the plan, and for most private employers, coverage questions go through the plan's ERISA claims process.

Is self-funded insurance good for employees?

It can be. Employees usually see the same ID card, network and claims process as in an insured plan, and the employer can add programs an insured policy may not allow, such as direct contracts or a separately contracted pharmacy benefit manager. Coverage depends on the plan document rather than state mandates, so employees should check the summary plan description.

Are self-funded plans subject to ERISA?

Yes, when a private-sector employer sponsors the plan. ERISA covers employee benefit plans of private employers, while government plans and most church plans are exempt. Under ERISA, the employer needs a written plan document and summary plan description, must follow claims and appeals rules, owes fiduciary duties to participants and files Form 5500 when required.

Do self-funded plans have to follow the ACA?

Yes, for most ACA group health plan rules. No self-funded plan can put lifetime or annual dollar limits on essential health benefits, and a plan that is not grandfathered must cover recommended preventive services without cost sharing. A self-funded plan does not have to cover the essential health benefits package required of small-group insurance, and the employer pays the PCORI fee itself.

What size company can self-fund?

There is no legal minimum. In the KFF 2025 Employer Health Benefits Survey, 80% of covered workers at firms with 200 or more workers were in self-funded plans, compared with 27% at firms with 10 to 199 workers, where level-funded plans are more common.

Sources

  1. 29 U.S. Code § 1102, Establishment of plan, Legal Information Institute, Cornell Law School
  2. 29 U.S. Code § 1144, Other laws (ERISA preemption), Legal Information Institute, Cornell Law School
  3. Form 5500 Series, U.S. Department of Labor, Employee Benefits Security Administration
  4. 29 CFR 2520.104-20, Limited exemption for certain small welfare plans, Legal Information Institute, Cornell Law School
  5. Patient-Centered Outcomes Research Trust Fund Fee, Questions and Answers, Internal Revenue Service
  6. 26 U.S. Code § 105, Amounts received under accident and health plans, Legal Information Institute, Cornell Law School
  7. An Employer's Guide to Group Health Continuation Coverage Under COBRA, U.S. Department of Labor, Employee Benefits Security Administration
  8. 29 U.S. Code § 1003, Coverage, Legal Information Institute, Cornell Law School
  9. 42 U.S. Code § 300gg-11, No lifetime or annual limits, Legal Information Institute, Cornell Law School
  10. 42 U.S. Code § 300gg-13, Coverage of preventive health services, Legal Information Institute, Cornell Law School
  11. 42 U.S. Code § 300gg-6, Comprehensive health insurance coverage, Legal Information Institute, Cornell Law School

This article is general information for employers, not legal or tax advice. Talk with your plan's legal counsel or tax advisor about your own situation.

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