Healthcare Changemakers, Benefits Advisors, Employers, Clinicians, and Innovators Invited to Access the Best Education and Experts in the Industry, All in One City, One Week

Nashville, Tenn. — March 17, 2026 — The Health Care Administrators Association (HCAA) and Health Rosetta are joining forces this summer to bring the healthcare industry's most forward-thinking professionals together in Nashville, Tennessee for an unprecedented week of education, collaboration, and innovation. The HCAA TPA Summit 2026, held July 27–29 at the Renaissance Hotel Nashville, and RosettaFest, held July 29–31 at the Gaylord Opryland Resort & Convention Center, represent two of the most impactful events in self-funded and high-performance healthcare, and for the first time, they are taking place in the same city during the same week.

For healthcare changemakers serious about cutting costs, improving outcomes, and staying at the forefront of industry transformation, Nashville this July is the place to be.

To read the full release visit here.

HCAA announced registration is open for Executive Forum 2026, scheduled for February 23-25, 2026 at the Marriott Rivercenter on the River Walk in San Antonio, Texas. This year’s conference, themed “Bold Enough to Lead. Brave Enough to Change,” will feature keynotes, panel discussions, and networking sessions for executive leaders in the self-funding community.

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ST. LOUIS – May 1, 2025 – The Health Care Administrators Association (HCAA), a leader in education, networking, resources and advocacy for the self-funding industry, today announced the keynote and general session speaker lineup for its TPA Summit 2025, to be held at the Hyatt Regency in Dallas, Texas on July 21-23, 2025. This three-day event will gather hundreds of third-party administrators (TPAs), brokers, benefit advisors and industry partners for a series of focused educational sessions set across the theme of “Lead. Inspire. Shape Tomorrow.”

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The Health Care Administrators Association (HCAA), a leader in education, networking, and advocacy for the self-funding industry, today announced the speaker lineup for Executive Forum 2025, scheduled for February 10-12, 2025 at the Bellagio in Las Vegas. This year’s conference, themed “Deep Roots, Bold Leaders & Soaring Success,” promises an immersive experience with thought-provoking keynotes, panels, and networking opportunities for executive leadership within the self-funding community.

Read the full press release here.

– The Health Care Administrators Association (HCAA), a leader in education, networking, resources and advocacy for the self-funding industry, today announced the keynote and general session speaker lineup for its TPA Summit 2024, to be held in St. Louis on July 15-17 at the Hyatt Regency at The Arch. This three-day event will gather hundreds of third-party administrators (TPAs) and other leaders from the self-insured community for a series of focused educational sessions set across the theme of “Winning in the New Transparent Marketplace: The Ethical Administrator.”

Read the full press release here.

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New Contraception Guidance Reminds TPAs of Obligations – and May Expand Them, Too

As most third party administrators (“TPAs”) know, the Affordable Care Act (“ACA”) imposes additional preventive care requirements on “non-grandfathered” health plans. One of those preventive care benefits relates to contraceptives.

Over the years there has been some uncertainty about which contraceptives, specifically, must be covered under the ACA. Prior IRS / DOL / HHS guidance provided helpful clarifications about the scope of this requirement. See, for example, these FAQs from January 2022: https://www.dol.gov/sites/dolgov/files/EBSA/about-ebsa/our-activities/resource-center/faqs/aca-part-51.pdf.

New Guidance “Strongly Encourages” TPAs to Do More. On June 27, 2022, the agencies issued an additional clarification – but one which strongly suggests that more is now required than prior guidance mandated. The new letter (available here: https://www.cms.gov/files/document/letter-plans-and-issuers-access-contraceptive-coverage.pdf) reiterates that a plan may use reasonable medical management techniques (e.g., a limit on the number of preventive care benefits), unless federal guidance provides otherwise. This was the position in final regulations from 2013.

Frequently Asked Questions (“FAQs”) from 2015 imposed some limits on the techniques that plans and TPAs could use. The FAQs stated that if a plan was using such a medical management technique, the process must be “easily accessible, transparent, and sufficiently expedient” so that it is not unduly burdensome. The TPA needed to process a review relating to what contraceptives a plan enrollee could receive in the “timeframe and manner that takes into account the nature of the claim (e.g., pre-service or post-service) and the medical exigencies involved for a claim involving urgent care.”

These references to ERISA’s claims and appeal procedures strongly suggested that a TPA could process the request for contraceptive coverage by simply following its typical, ERISA-mandated claims and appeal procedures. However, the June 2022 letter “strongly encourages” plans and TPAs to NOT follow their typical process for claims and appeals. Rather, the letter says just the opposite – plans and TPAs should “not requir[e] individuals to appeal an adverse benefit determination for a contraceptive using the plan’s or issuer’s internal claims and appeals process as the means to obtain an exception”.

Instead, the letter strongly encourages plans and TPAs to create a brand-new process. The agencies suggest that plans and TPAs create a “standard form and instructions” for plan enrollees to seek an exception to the TPA’s medical management techniques. The agencies suggest that plans and TPAs use the Medicare Coverage Determination Request Form as a possible template for this alternative process. That form is available here: https://www.cms.gov/Medicare/Appeals-and-Grievances/MedPrescriptDrugApplGriev/CoverageDeterminations-. It is not clear whether many TPAs have such a process in place right now, given that the prior FAQs did not require – or strongly encourage – such a process.

The agencies also stated – apparently for the first time – that any such new process or new form must be included in “plan documentation and online resources”. This would presumably include a summary plan description (“SPD”). Thus, if TPAs implement such a process for a client, they should make sure that the client includes that process in its SPD and other online resources (perhaps an intranet site which has the SPD).

Summary. The new letter falls into one of the “gray areas” that sometimes happen. The federal agencies did not specifically mandate the new process, but they did “strongly encourage” it. This suggests that it is perhaps a “soft mandate”. That is, the agencies may be looking specifically for plans and TPAs to have it in place. If they do, the agencies will likely find that the process is acceptable. If they do not, it seems like the agencies may find a violation, even if the plan and TPA could argue that the new process was not technically required. Thus, TPAs should consider implementing this process, even if they have an argument that it is not technically mandated.

On Friday, June 24, 2022, the U.S. Supreme Court issued its decision in Dobbs v. Jackson Women’s Health. Overturning two prior precedents, Roe v. Wade and Casey v. Planned Parenthood, the Dobbs decision permits states to regulate and/or prohibit access to abortion at any stage of pregnancy. Following the decision, it is expected that at least 26 states will ban or severely curtail access to abortion.

Dobbs will likely have an immediate and significant impact on third party administrators (“TPAs”), pharmacy benefit managers (“PBMs”) and employers which sponsor group health plans. We discuss the most-pressing concerns below.

Aiding and Abetting Laws. Most employer-sponsored group health plans provide at least some coverage for abortions. In fact, the federal Pregnancy Discrimination Act (“PDA”) requires that many group health plans provide abortion, if the life of the mother is endangered. And, the PDA generally requires that complications of other abortions also be covered. Note that the PDA does have some exceptions, such as for small employers with less than 15 employees.

TPAs, PBMs and employers generally have not needed to consider state laws which limit abortions. Now, it appears that they should. Many of these laws are old – some are over 100 years old. Prior to Dobbs, the laws were almost certainly not enforceable. After Dobbs, the laws most likely are enforceable, although some are being challenged and a few have been put on a temporary hold by courts.

Many state laws impose civil or criminal penalties on health care providers. Those penalties are not likely to impact TPAs. However, some of the state laws also impose those penalties on other third parties who assist in the provision of abortions. These “aider and abettor” law pose a risk to TPAs, PBMs and employers which sponsor health plans.

For example, Alabama has a law (here:  http://alisondb.legislature.state.al.us/alison/CodeOfAlabama/1975/13A-13-7.htm) which says:

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Inducing or attempting to induce abortion, miscarriage or premature delivery of woman.

Any person who willfully administers to any pregnant woman any drug or substance or uses or employs any instrument or other means to induce an abortion, miscarriage or premature delivery or aids, abets or prescribes for the same, unless the same is necessary to preserve her life or health and done for that purpose, shall on conviction be fined not less than $100.00 nor more than $1,000.00 and may also be imprisoned in the county jail or sentenced to hard labor for the county for not more than 12 months.

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Does a TPA or PBM “aid” or “abet” an abortion when it processes a claim relating to a pregnant woman’s drug to induce an abortion, miscarriage or premature deliver? Does an employer “induce” an abortion, miscarriage or premature delivery when it promises, under the health plan, to pay for that result? The answer is not clear. However, it appears that an aggressive district attorney in Alabama could at least make such an argument. Note that the law imposes both civil and criminal penalties (including the penalty of “hard labor” if convicted).

Some states have tried to tie their laws even more-specifically to insurance or, perhaps, even to self-funded group health plans. For example, Texas has a law (see here: https://capitol.texas.gov/tlodocs/87R/billtext/pdf/SB00008F.pdf) which provides a penalty for any person who “aids or abets the performance or inducement of an abortion, including paying for or reimbursing the costs of an abortion through insurance or otherwise”.

Would a TPA which approves an abortion claim, per the terms of its client’s health plan, be viewed as “reimbursing” the costs of the abortion “through insurance or otherwise”? On its face, this is a plausible reading of the Texas law.

TPAs and PBMs are, arguably, in a more-vulnerable position than employers are with respect to these issues. TPAs and PBMs sometimes have a more-difficult time arguing that ERISA preempts a state law. And a TPA or PBM is vulnerable to pressure that it could lose its license in a particular state if it violates that state’s law. Losing a license in a particular state could also require the TPA or PBM to inform other states of the loss of the license. That could cause a loss of its licenses in other states.

Preemption. It is possible that some of these state laws could be preempted by ERISA, at least for ERISA-covered plans. It also seems possible that abortions which are strictly limited to those mandated by the PDA might be preempted by the PDA (a federal law). That raises the question of whether a TPA should work with its clients to ensure that the health plan only covers PDA-covered abortions. That could eliminate certain “elective” abortions. Presumably some clients would not approve of such a change, while others may welcome it.

Unfortunately, it probably is not possible to assume that federal law preemption will completely resolve these issues. Some states – such as Alabama, noted above – impose criminal penalties in this context. ERISA generally does not preempt state criminal laws of general applicability. Thus, it does not seem possible to simply ignore these issues.

Extraterritorial Issues. Another related question is which state’s law controls. For example, suppose that an employer is based in California. It has physical locations in four other states. Some of those states have abortion restrictions. But others do not.

If the TPA processes a claim for the health plan, must the TPA take into account all five state laws, and apply the most-restrictive law? Should the TPA base its processing on the state where the company’s headquarters are? Should the TPA only look to the state where the abortion service was provided?

Perhaps the TPA should look to the state where the plan enrollees live. If so, is the analysis based on where the employee lives (e.g., an employee who lives in California), or where a dependent or spouse lives (e.g., a college student whose parents live in California, while the college student lives in Alabama)? Does the TPA even have enough information to make this determination?

All of these questions are important. But the answers are not yet clear. They will require an analysis by the TPA and perhaps a discussion with the TPA’s clients about next steps, taking into account these newly-created state law risks.

Travel-Related Expenses. Many plan sponsors have already announced that they will be adding a travel benefit to allow covered individuals access to abortion services if they live in a state where abortion is prohibited. Travel benefits could be provided in a number of ways, including group health plans, health reimbursement arrangements (“HRAs”), employee assistance programs (“EAPs”) and taxable reimbursement programs, or even in some other alternative.

Each option comes with pros and cons. An EAP and a taxable reimbursement program limited to medical travel would still be considered ERISA benefits and, as such, would require additional administration. Further, an EAP would need to qualify as an “excepted benefit” in order to satisfy ACA requirements. As such, the direct group health plan coverage and HRA reimbursement seem to be the most viable options.

However, some employers have expressed interest in a broader arrangement under which a wide variety of travel expenses could be covered – not just for abortion-related travel expenses. The thinking is that this type of “broad benefit plan” would help the employer argue that it is not “aiding or abetting” an abortion, if the broad benefit plan is not limited to only abortion-related benefits. It is not clear if this argument would succeed. But it seems to provide an additional argument for employers.

Group Health Plan Coverage. Plan sponsors may be able to provide travel-related benefits under currently existing group health plans, which would allow the sponsor to implement the benefit with minimal administration changes. Furthermore, travel-related expenses may not be considered “essential health benefits” under state benchmark plans, which would allow sponsors to cap total travel benefits at a certain dollar amount.

Plan sponsors should also consider the risk under the Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”) of providing travel benefits for medical/surgical procedures and not mental health and substance use disorder treatment. One way to address the MHPAEA concern could be to provide a generally applicable travel benefit that would apply to any covered service under the plan, or perhaps to benefits which have significant access issues at the state or local level.

The limits under section 213 of the Internal Revenue Code (the “Code”) for reimbursement of medical related travel (e.g., $50 per night for lodging) would apply, but plan sponsors could provide a more robust taxable benefit. If taxable benefits will be provided, the plan sponsor should discuss with the TPA and PBM who will track and report the taxable benefits.

Health Reimbursement Arrangement Coverage. Plan sponsors could also provide reimbursement for travel and lodging expenses through an integrated HRA. However, as a group health plan, an HRA would have similar issues as the direct group health plan coverage discussed above and an HRA would have start-up and administrative costs in the event the sponsor does not already have one in place. Furthermore, any reimbursement provided through an HRA would be subject to the limits under Code section 213, without the ability to provide the greater taxable benefit.

Summary. The Dobbs decision poses immediate and novel concerns for TPAs, PBMs and employers. All involved should quickly review these issues and determine their strategies to minimize risk.

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