News & Analysis as of

Third Party Administrators

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Payroll Providers 401(k) TPAs Are A Convenience Trap

I’ve been around this business long enough to know that not every opinion ages well. Some soften, some mature, and some just fade away as experience replaces instinct. I used to think rap music had nothing to offer. I was...more

Polsinelli

Louisiana Insurance Department Issues Bulletin Emphasizing TPA Due Diligence Obligations Regarding Unlicensed Insurance Entities

Polsinelli on

Key Takeaways - The Louisiana Insurance Department issued Bulletin 2026-07 reminding TPAs of their due diligence obligations when entering into agreements with entities offering insurance products or insurance services in...more

Goldberg Segalla

New RFA-2 Electronic Submission Mandate from NYS Workers’ Compensation Board

Goldberg Segalla on

At this time, the New York State Workers’ Compensation Board requires all Request for Further Action by Insurer/Employer forms (Form RFA-2) be submitted electronically via eCase – paper RFA-2 forms are no longer accepted or...more

Freeman Mathis & Gary

Arizona Court of Appeals emphasizes third-party administrators have no direct liability to insureds for bad faith

Freeman Mathis & Gary on

In Wagner v. Arizona Municipal Risk Retention Pool, the Arizona Court of Appeals has reiterated that third party administrators are not liable to insureds for bad faith where there is no contractual nexus between the third...more

Weber Gallagher Simpson Stapleton Fires &...

Commonwealth Court Bars Supplier of Medical Goods from Challenging Amounts Paid Under Workers’ Compensation Through Fee Reviews

The Commonwealth Court’s groundbreaking decision has found against Scomed, ruling that suppliers of medical goods such as Scomed (as opposed to providers of healthcare services), are not “health care providers,” and as such...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Why Providers Keep Racing to the Bottom on Fees

The retirement plan industry loves to talk about value, but it keeps pricing itself as if value doesn’t matter. Nowhere is this more obvious than in the constant race to the bottom on provider fees. TPAs, recordkeepers, and...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

What TPAs Get Sued For (Hint: It’s Not the Calculator)

As a retirement plan attorney, I can tell you this with certainty: TPAs are rarely sued because they miscalculated a contribution by a few dollars. Math errors happen. The industry knows how to fix them. Lawsuits don’t come...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Niche Markets: Doctors, Law Firms, Unions, and Family Businesses

Every plan provider says the same thing: “We work with everyone.” That sounds inclusive, but it’s terrible marketing and even worse strategy. The most successful TPAs and advisors I know don’t chase everyone—they own niches....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Hidden Risk of Provider Conflicts Inside PEPs

PEPs were sold to the retirement plan industry as the answer to everything—lower costs, better governance, and less fiduciary risk for employers. What doesn’t get enough attention is the new layer of conflicts that PEPs can...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

In the PEP World, the Power to Assign Can Be the Power to Destroy

Chief Justice John Marshall famously wrote in McCulloch v. Marylandthat “the power to tax is the power to destroy.” In today’s retirement plan business, I’d argue there’s a modern parallel: the power to assign a financial...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

What a 401(k) TPA Does and the Misconceptions That Never Seem to Die

I ’ve been in the 401(k) business long enough to remember when thirdparty administrators were mysterious creatures that lived somewhere between the recordkeeper and the plan sponsor, occasionally emerging to ask for census...more

Polsinelli

Texas Regulatory Action Underscores Insurer Accountability for TPA Compliance

Polsinelli on

Key Takeaways: A Florida-based insurer was recently fined by the Texas Department of Insurance for failing to ensure the competent administration of its programs by working with an unlicensed TPA and failing to conduct...more

Groom Law Group, Chartered

Drug Pricing and Plan Contracting Practices Under Scrutiny: PBM and TPA Reforms in the Consolidated Appropriations Act, 2026

On February 3, 2026, Congress passed and the President signed the Consolidated Appropriations Act, 2026 (“CAA 26”), a legislative package that funds several federal agencies, including the Departments of Labor and Health and...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Why Being “Good at What You Do” Isn’t Enough Anymore

For years, plan providers survived on a simple premise: do solid work, keep clients happy, and the business will come. That world doesn’t exist anymore....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

When Your Providers Disagree, It’s Still Your Problem

Plan sponsors are often surprised to learn that when their advisor, TPA, and recordkeeper disagree, the conflict doesn’t protect the plan sponsor—it exposes them....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Recordkeeper, TPA, Advisor: Who Owns the Mistake When Something Breaks?

When a retirement plan error surfaces, the first reaction is almost always the same: finger-pointing. The sponsor looks to the advisor. The advisor looks to the TPA. The TPA looks to the recordkeeper. And somewhere in the...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Most Ignored Document: Your Plan Document

Every plan sponsor owns a plan document. Very few read it. Fewer understand it. And almost none use it as the operating manual it was designed to be....more

Fisher Phillips

The “Ghost Network” Problem: The Key Questions Employers Can Ask to Avoid Little-Known Benefits Risk

Fisher Phillips on

A recent federal district court decision highlights a little known but significant risk faced by employers with welfare benefit plans that rely on medical provider and facility networks supplied by insurance carriers or...more

Polsinelli

Alaska Eliminates TPA Licensing Exemptions, Expanding Licensing Requirements

Polsinelli on

Key Takeaways: Alaska’s new TPA licensing requirements take effect Jan. 1, 2026. Senate Bill 132 eliminates a key exemptions and expands who must be licensed as a Third Party Administrator in the state....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Fiduciary Gamechanger: The Cornell 403(b) Decision and What It Means for You

If after decades of advising retirement-plans I learned one thing, it’s this: The law doesn’t reward you for almost doing everything right — it rewards you for doing it right, and documenting you did it. So when I read the...more

Verrill

New Maine Law Gives Employers Leverage when Negotiating Audit Rights

Verrill on

Maine’s new Act to Improve Accountability and Understanding of Data in Insurance Transactions (the “Audit Act” or “Act”) prohibits Maine-licensed third party administrators (“TPAs”) and pharmacy benefit managers (“PBMs”) from...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

That 401(k) Conference Heads to Chicago and Denver!

If you’ve been to one of That 401(k) Conferences before, you already know it’s not your typical industry event. No fluorescent hotel ballroom, no generic panel on “fiduciary best practices,” and definitely no dry chicken...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

When $1.8 Million Becomes the Fine Print in the 401(k) Fee-Fight

Here’s a story straight from the trenches of the 401(k) world: the parties in a long-running excessive-fee lawsuit over the $2.6 billion Ferguson Enterprises LLC 401(k) plan have reached a settlement for $1.8 million....more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The 401(k) Hunger Games For Plan Providers

I f you’ve worked in the 401(k) business long enough, you know that survival isn’t guaranteed. It’s a world that’s part Wall Street, part Mad Max, and part The Hunger Games, where recordkeepers merge faster than tributes...more

Constangy, Brooks, Smith & Prophete, LLP

ADA-FMLA Hell: 4 things this employer (allegedly) did wrong

EEOC allegations ring true. The following is based only on the allegations in a lawsuit that was filed this week by the Equal Employment Opportunity Commission. The employer hasn’t had a chance to give its side of the...more

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