Insights

Benefits & Accountability

Six major employers say they couldn’t get usable claims data. Can you?

The Aramark–UnitedHealth suit concerns alleged improper claims payments. The broader lesson is about access—and it matters whether you have 200 employees or 200,000.

· Brian Ullrich · EPIQ Insights

Magnifying glass over illustrative claims records beside an open binder on a charcoal desk
Editorial illustration; not actual employer or employee claims records.

Read past the headlines

On October 20, 2026, Aramark, Kraft Heinz, W.W. Grainger, Whirlpool, Ralph Lauren, and Sterling Jewelers, along with related benefit plans and committees, sued UnitedHealth Group and affiliates in federal court in the Eastern District of Texas. [1]

These are substantial employers with the resources to scrutinize their health plans. Yet their complaint alleges improper claims payments, undisclosed fees, and problems obtaining usable claims data from their administrator. [2]

The alleged conduct includes “cross-plan offsetting”: recovering an overpayment associated with one plan by reducing a provider payment associated with another. The concern for employers is whether a recovery actually benefits the plan whose money was overpaid. That is a question to ask—not an assumption to make about your own administrator.

These are allegations, not established findings of wrongdoing. The lawsuit does not prove that your plan has the same problems.

But one issue deserves attention regardless of how the case is resolved: the employers say data-access problems impaired their ability to monitor what was happening to plan money. Their experiences were not identical; reporting describes incomplete or unusable information and, for some plaintiffs, no usable data. They are seeking access to claims records. [2]

What an 835 file is—and why you should care

An 835 is the standard electronic health care claim-payment and remittance-advice transaction. It can explain a payment and the adjustments that reconcile billed charges with what was paid. A transaction may cover multiple claims; it is not necessarily a separate file for each paid claim. [4]

If you fund your own plan, that is your money moving. Think of remittance information as part of the receipt—not a substitute for the complete claims record, the contract, or an audit.

A monthly claims report, a large-claim list, and a renewal can be useful. But they are summaries. They do not necessarily give you the claim-line detail, payment adjustments, and recovery information needed to test how your plan is being administered.

The practical question is not simply “Do we receive reports?” It is “Can our chosen reviewer obtain the underlying information needed to verify those reports?”

This is not just a big-company problem

It is tempting to read this as a Fortune 500 story. It isn’t. A mid-market employer also needs to understand what its administrative services agreement allows—and what it leaves uncertain.

Check whether your agreement promises usable claims data or only predefined reports. Look for restrictions on delivery schedules, auditors, review scope, and the cost of obtaining files. Those are contract questions to investigate, not assumptions about every third-party administrator.

For plans subject to ERISA, hiring a service provider does not eliminate the relevant fiduciaries’ responsibilities. Department of Labor guidance describes duties to prudently select and monitor providers. The precise duties depend on the role and circumstances, but effective oversight requires meaningful information. [5]

Cost pressure makes that information more important. WTW’s 2026 Best Practices in Healthcare Survey, released October 28, reported that surveyed employers projected 2027 healthcare costs to rise 11.1% before plan changes and 9.7% after them. High-cost claimants were cited as a cost pressure by 86% of employers. These are survey projections—not a prediction for every plan. [3]

When costs are climbing, avoidable payment errors—if present—add another burden. You cannot establish whether they exist by looking only at the renewal percentage.

Five questions to ask before your next renewal

Pull your administrative services agreement (ASA), fee schedules, and your TPA’s data policy. Then ask:

  1. Who owns the claims data? Ask for clear contract language addressing ownership, access, and permitted use. “Has access to reports” is not the same as an enforceable right to obtain usable underlying records. Have counsel review the wording.
  2. What format, how often, and at what cost? Ask for claim-line detail and relevant remittance data, including 835 transactions where applicable, on a regular schedule in a usable standard format. Confirm that it can go to a qualified designee you choose. Watch for per-file fees or data-release charges.
  3. What are your audit rights? Clarify frequency, scope, auditor selection, and who pays. Ask whether a full electronic claims review is permitted rather than only a limited sample—and identify any contractual restrictions before renewal.
  4. How are overpayments recovered, and where does the money go? Ask in writing whether recoveries involve other clients’ claims, when recovered money is credited to your plan, and whether the TPA retains a percentage.
  5. What does the TPA earn beyond the administrative fee? Request an itemized explanation of network access fees, cost-containment shared savings, recovery fees, and other compensation. If the answer is “it’s in the fee schedule,” get the schedule.

If an answer is vague, put the question in writing and ask again. How plainly the administrator responds tells you something about the working relationship you are renewing.

Data access must also respect employee privacy. Arrange appropriate authorization, safeguards, and secure delivery to the plan or its qualified reviewer; do not request identifiable health information for ordinary employment decisions.

What we do

Our benefits consulting practice is flat-fee and does not take carrier or vendor compensation. When we ask a TPA for claim-level data, we are not protecting a commission stream.

We use our SAIL™ analytics to examine claims, trends, and payment patterns that summary reports can smooth over. That work starts with usable data, appropriate permissions, and a clear understanding of the plan’s contractual rights—not a promise that every review will uncover improper payments.

The lesson from this lawsuit is not to assume your administrator is doing something wrong. It is to make sure you can look.

Sources & further reading

  1. Court docket: Aramark Services Inc. et al. v. United Health Group Incorporated et al. (filed October 20, 2026)
  2. Becker’s Hospital Review: Employers sue UnitedHealth over alleged improper claim approvals
  3. WTW: 2026 Best Practices in Healthcare Survey (October 28, 2026)
  4. CMS: Health care payment and remittance advice
  5. U.S. Department of Labor: Understanding your fiduciary responsibilities under a group health plan

Can you see what your plan is paying?

If you are self-funded—or considering it—and have never reviewed your claim-level data, start with a conversation about what your contract lets you see and what may be missing.

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