How to choose a TPA: questions to ask

Updated October 21, 2026

To choose a TPA, write down what your plan needs, shortlist administrators that serve your plan type and states, send each one the same request for proposal, check references from similar plans, and negotiate the contract before you sign. For an ERISA plan, hiring a service provider is itself a fiduciary function, so document each step and the reasons for your choice.

What steps should you follow to choose a TPA?

Choosing a TPA works best as five steps, each narrowing the next: define your needs, build a shortlist, run an RFP, check references, then negotiate.

1. Define what your plan needs

Start with the facts a TPA will price and staff against:

• Plan type. A single-employer self-funded plan, a level-funded plan, a multiple employer welfare arrangement (MEWA) or association plan, a Taft-Hartley fund, a public entity, a church plan, a health share ministry or a captive. The rules differ by type. ERISA does not cover public sector or church-sponsored plans, for example, so ask for experience with your type specifically.
• Size. Enrolled employees and members today, and expected growth.
• States. Where members live and work. This drives network needs and where the TPA may need a license or registration. Texas, for one, lists registered TPAs through its insurance department.
• Services. Claims, eligibility, member service, network access, utilization review, care management, COBRA, account-based plans and stop-loss coordination.
• Carve-outs. A separate pharmacy benefit manager, behavioral health vendor, dental or vision plan, or care management program that the TPA must exchange data with.

2. Build a shortlist

Use the directory to find administrators that say they serve your plan type and states. Browse all TPAs or TPAs by state, then filter by plan type, such as self-funded employer plans, level-funded plans, MEWAs and associations, Taft-Hartley funds, public sector plans, church plans, health share ministries or captives. Add service filters like stop-loss coordination or pharmacy benefits, and ownership filters for independent or carrier-owned TPAs. A listing shows what a TPA says it offers, so confirm it in the RFP.

3. Run an RFP

DOL suggests that a fiduciary survey several providers, asking for the same information and providing the same requirements, so the answers can be compared. Give every bidder the same package: census, plan document and summary plan description (SPD), recent claims experience, current fees, stop-loss terms, network and carve-out vendors. Ask about the firm itself, including its financial condition, its experience with plans of similar size and complexity, and any recent litigation or enforcement action.

4. Check references

Ask for references from plans like yours in type, size, states and network, and include at least one client that has left. Ask how implementation went, what errors came up and how they were fixed, and whether reports arrive on time.

5. Negotiate and document

Negotiate the contract terms below, then keep a written record. DOL notes that prudence focuses on process, so fiduciaries should document decisions and the basis for them, and that an employer should review its providers at reasonable intervals after hiring them.

What questions should you ask a TPA?

Group your questions by the work the TPA will do, and ask every finalist the same ones.

Claims accuracy and turnaround

Ask what the TPA measures and reports, not just for a headline number.

• Which accuracy measures do you track, how do you define each, and who audits them on what sample?
• Does turnaround run from receipt to payment or to decision, and does it count all claims or only clean ones?
• How do you meet the claims procedure deadlines? A plan must decide post-service claims within 30 days, pre-service claims within 15 days and urgent care claims within 72 hours.
• How much volume is paid without manual review, and how do you check it?
• How do you find and recover overpayments, and how old is your oldest pended claim?

Member and provider service

Ask how members and providers reach the TPA and how problems get resolved. DOL lists procedures for resolving questions and complaints, and enrollee satisfaction statistics among the things to evaluate.

• What are your hours, channels and languages, and is the team dedicated to our plan?
• How are complaints logged, resolved and reported to us?
• How do providers check eligibility, benefits and claim status?
• Plans must have a process for answering questions about a provider’s network status within one business day. Who does that for us?

Technology, reporting and claims data

Ask how the TPA’s systems work, what you will see, and who controls the data.

• Which claims system do you run? Is it licensed or built in-house, when was it last upgraded, and which platform would we be on?
• Which reports come monthly, and how fast are ad hoc requests filled?
• In what format and how often can we, our consultant and our stop-loss carrier get claim-level data? Contracts with a TPA may not restrict a plan from electronically accessing de-identified claims data, including allowed amounts, provider information and service codes.
• What are your security standards and audit results, and have you had a breach? DOL confirmed that its cybersecurity guidance applies to health and welfare plans, and its tips for hiring a service provider cover these questions and cyber insurance.

Compliance support

Ask which tasks the TPA performs, which it only supports, and which stay with you.

• Transparency in Coverage. The rules require machine-readable files of in-network rates, out-of-network allowed amounts and drug prices, plus a cost-sharing tool. If a TPA agrees to post the files and fails, the plan violates the disclosure requirements. Ask who posts the files and how the TPA will handle the 2026 amendments.
• No Surprises Act. Plans must cover most emergency services as in-network, cap cost sharing at in-network levels in protected situations, keep directories accurate and print deductibles and out-of-pocket maximums on ID cards. Ask how the TPA flags protected claims.
• Mental health parity (MHPAEA). The Consolidated Appropriations Act, 2021 requires plans to perform and document comparative analyses of nonquantitative treatment limitations. The agencies paused enforcement of the new provisions in the 2024 final rule but said the statutory obligations continue, and DOL’s September 2026 bulletin focuses enforcement on separate treatment limitations, medical necessity and network adequacy. DOL’s 2023 report to Congress says it prioritizes violations caused by service providers. Ask whether the TPA prepares the analysis and what data it supplies, and confirm the split with your benefits counsel.
• Other filings. Ask who submits the gag clause attestation, due each December 31, and the prescription drug data collection (RxDC) report.

Stop-loss, networks and fees

Ask how the TPA works with your stop-loss carrier and networks, and exactly what you will pay.

• Stop-loss. Some stop-loss insurers require a specific TPA, and some end coverage if the employer changes TPAs. Ask whether any proposed policy is tied to the TPA, how large claims are reported and filed, and how the plan document is kept consistent with the policy. The employer remains responsible for gaps or conflicts between the two. Compare TPAs that list stop-loss coordination.
• Networks. Ask which networks the TPA can access, whether it supports direct contracts, and whether it offers network access or reference-based pricing. The reference-based pricing guide explains that model.
• Fees. Ask which services the fee covers and which it does not, and whether the TPA receives third-party compensation such as finder’s fees, commissions or revenue sharing. The guide to TPA fees and how they are quoted covers the common structures.

What should a TPA contract include?

A TPA contract should spell out who does what, how performance is checked, and how the relationship ends.

On fiduciary status, a TPA doing only ministerial tasks is not a fiduciary, but that may change if it exercises discretion over benefit eligibility. A fiduciary can set up an agreement so the provider assumes liability for selected functions, but must still monitor it.

On exit, the TPA contract should address run-out claims, run-in claims and the transition when the contract is renewed or terminated. Ask for the TPA’s business associate agreement. Under HIPAA, that kind of contract must require the business associate, at termination and if feasible, to return or destroy the protected health information it holds. Agree on the data return format before that point. The guide to switching TPAs covers the handoff.

What are the red flags when choosing a TPA?

Treat any of these as a reason to probe further or move on:

• It resists giving you claim-level data, or wants to charge you to see your own claims.
• It cannot explain how it is paid, including any third-party compensation.
• The stop-loss offer is tied to the TPA, or coverage ends if you change TPAs.
• Its compliance answers are vague, or it will not put compliance duties in writing.
• The contract limits its responsibility for security breaches.
• It quotes accuracy figures it cannot define or let you audit.
• It has no references from plans like yours.
• It will not discuss pending litigation or enforcement actions, or its required licenses have lapsed.
• Run-out and data return terms are left blank or priced only at termination.