A newly filed class action against Cigna Health and Life Insurance Company puts a spotlight on a common but often overlooked feature of administrative services only (ASO) agreements: “shared savings” fees that pay the third-party administrator (TPA) a percentage of the amount it “saves” the plan on out-of-network claims. The complaint, Kreutzmann v. Cigna Health…

On September 17, 2026, the Second Circuit handed down a significant decision for self-insured group health plans, holding that the No Surprises Act (“NSA”) does not create a private right of action for out-of-network providers to enforce payment awards obtained through the independent dispute resolution (“IDR”) process. The ruling in East Coast Advanced Plastic Surgery…

The Departments of Health and Human Services, Labor, and the Treasury (Departments) recently released the Federal Independent Dispute Resolution (IDR) public use files (PUF) and supplemental tables for the third and fourth quarters of 2025, and the numbers should get the attention of every plan sponsor and fiduciary overseeing a self-insured group health plan. The…