So, I have questions, but you know feel free to expand where you want to, you know, and then if there's stuff that we didn't cover, I thought we were going to talk about what's going on. Yeah. And then one last thing, I'm just going to make sure we can keep the cord on, yeah, hidden. Yep. I'm going to tuck it behind the pillow, is that right? Perfect. And look at me, I didn't wear stripes, you know, I move. And do you want me to repeat the question or like, will your questions be, or they'll be like, you'll probably have some like, talk over something when you cut things together or whatever, you voice over, yeah. So, any way that we can like, not have you have to think about 8 million things while you're trying to answer. Actually try to answer a question, uh-huh. So, what I'm going to do is start with the basics, so that I don't forget it. So. That sounds good. Start with, what is a self-funded health plan? A self-funded health plan is when the employer pays for the healthcare costs instead of paying premiums to an insurance company that is paying the claims. And what is a third party administrator? What happens when an employer wants to self-fund is that they don't generally have expertise in administering insurance or healthcare claims processing. So, they hire an insurance company to act as that administrator, to be the third party administrator. For consumers, the employees who are getting the healthcare access, this can be very confusing because it looks like they have insurance because a third party administrator is processing the claims, but they actually have self-funded care. And you did say that the third party administrator is an insurance company, but this plan is not health insurance. Can you help us understand that? Correct. And it is very confusing. So I will do my best to try to make sense of this. And this is what we do with the Center for Patient Partnerships is really help consumers understand why they're having trouble accessing care and help them access that care. So an insurance company is acting in an administrative capacity when there being a third party administrator. They are processing claims using money that the employer is still holding. They are not processing those claims using their own money that they've collected in premiums. Now, oftentimes the contract that they're using to make that decision can look the same, whether it's an insurance product or it's a self-funded product, but they are paying using employer dollars, not the insurance company dollars. I don't know if that helped. So part of what I think helped me understand it the best when we spoke ahead of time was this difference between who is both taking in the profit, but also who is taking on the risk? Can you break that down? Absolutely. So the reason that many employers purchase insurance for their employees through an insurance company is the insurance company is holding all the risk. The insurance company is looking at actuarial tables is determining how much money they need to charge that employer to cover all the claims for that group of employees. And if they're wrong, they're the ones who are going to make less profits or lose money. The reason that self-funded plans came about is that employers realized they were paying a fixed amount to the insurance company, and then it was the insurance company that while holding the risk could make the profit. And so employers realized, hey, if we hold all that money ourselves and only pay a certain percentage in claims, we're keeping that profit. We're not giving that profit away to an insurance company. And in order for the employer to hold that risk, they're buying some stop loss insurance. So they are buying a little bit of insurance in case they're wrong about the risk. But they're maximizing their ability to keep that profit. Is this not considered insurance because of how it's formatted, or is it not considered insurance because of how it's regulated? So the reason that as a health advocate, I care about this and I have concerns about self-funded plans is that a self-funded plan is not insurance. And being insurance is what triggers state regulation. So from a consumer perspective lens, if it is insurance, then in Wisconsin, for example, the Office of Commissioner of Insurance is regulating all companies selling insurance. And there are rules those companies need to follow in terms of mandatory benefits they need to cover in terms of internal insurance appeal opportunities, in terms of oversight for grievances. So you have to be doing business under the state in good faith. When a plan is self-funded and therefore not insurance, it is regulated only by the federal government under ERISA. And so there is some protections, but it's not the same as if it's an insurance product where it's regulated both by the state government and the federal government. So there's less protections for consumers. In some cases, it's called self-insurance, and patients still get a card that can have united health on it, Blue Cross on it. That is even more confusing. So even though they have a card, even though in some cases people refer to it as self-insured, it is still not insurance. Correct. And it takes advocates and patients sometimes quite a bit of time to parse out and figure out that it is not insurance. And the reason that the patient has that card that says the insurance company name on it is that is the insurance company that is acting as that third party administrator. And so at the beginning, it might not seem like a problem, but what happens is if there are claims being denied, the protections that that consumer has are reduced in self-funded plans. So they might be able to do one internal appeal, but they won't, for example, qualify for an external appeal. And as a consumer protection health advocacy center, we want patients to have as many appeal rights, as many protection opportunities as possible. And what's good about an external appeal is that the person making that decision is an independent third party. It's not the insurance company or the third party administrator deciding about a claim with which they're either paying for on behalf of themselves or the employer. And internal appeal versus external appeal. An internal appeal would be a claim is denied by your employer slash the third party administrator. So your only option is to go to those exact people who turned you down and say, we think this was wrong. Actually, under the contract, right, under the care contract you've provided me, you should have covered that medication. And here's why. Here's why it was medically necessary. Or here's why in the contract it should have been covered. And you are right. It is the person who told you it wasn't covered who is then hopefully saying, oh, we were wrong. You're right. It's not a third party. It's not an independent review of that denial. Maybe let's not say third party because then it's confusing. Right. So internal appeal means who is reviewing it? It is being reviewed by that TPA, that third party administrator or the insurance company if it's an insured product. Okay. Do you want to ask the question just with like for self-funded, do you want to say if it's a self-funded plan, an internal appeal means what? The third party administrator is reviewing the denial that they made on behalf of the employer. And even though the third party administrator is processing these claims and the internal appeal, the employer, because they are paying, can't they change their mind? Can't they do whatever they want to do? Theoretically, but you'd have some issues of fairness, right? So if I'm the employer, if I'm the human resources department for the employer, I can't say, well, in this case, for this one employee, I'll say yes, right, that I would need to say, oh my gosh, we made a mistake here or the third party administrator has made a decision that's against what we intended, right? That's not what we meant by this plan that we have. And of course, they could do that. The concern I have as a health advocate is that a large motivation for having a self-funded plan is to save money, and the place that the money is saved is in paying out less claims. That is, you know, if you look at all the different expenses, that is a variable cost. That is not one of the fixed costs, such as the administrative fee being paid to the third party administrator or the stop loss insurance, right? The room for profit is paying out less of your employee's claims. So someone with a self-funded plan has far less options in terms of a claim being denied and then having recourse. Correct. How is that different under actual health insurance? So because health insurance is regulated by states, after you've exhausted an internal appeal, you can also then file an external appeal, and that is an independent review organization is looking at that. And theoretically, that entity doesn't benefit from upholding that denial, right? There's no money on the table that they could potentially be saving because of that. The other thing that consumers have for insurance products is the ability to make a formal grievance or complaint to the state regulator. And therefore, under those circumstances, the state's required to look at the business practices for the insurance company or, and in that case, if there's bad faith or some right action that's not appropriate, they can issue them corrective action. So you've got both the individual on my claim, I'm doing an external appeal, and also I can file a formal grievance, you know, over their behavior. If self-funded plans are federally regulated, is there not federal recourse to challenge claims? There is the same federal recourse that also exists for insurance products, but in our experience, it's not the same level of rigor or sort of the feedback loop. The Kaiser article you sent me said something about, because of ERISA, some people would have to go to the Department of Labor. Correct. So ERISA writes, so the federal entity, the federal department is the Department of Labor that's regulating self-funded plans, because if you think about it, because it's the employer who's paying the claims, it's about employee-employer relationships. So it's regulated by the Department of Labor. All of this is, as we've said, a very confusing thing. If I were someone looking for a job, is this something that I could have any input over? If I am looking for a job or starting a new job, do I have kind of any ability to make informed decisions, or do I kind of have to take what I can get? I think it depends. So I think it depends on what kind of job you're looking for and what kind of employers you might be able to work for. So, for example, large employers, over 90% of very large firms, self-fund. And if we're talking about a self-funded situation, there's not a choice then of, right, you're in the pool. You are paying a premium, and that money's going into this big savings account that's being used. Might you be able to voice to your employer that you're concerned that there's no choice? Might you be able to provide feedback to your employer in a collective way with other employees that you want them to use a different third-party administrator, or you really think that you really believe they should cover this benefit, right? Sure. Do I think that would be impactful? I would like to hope so. We are seeing a tremendous amount of consolidation just generally, right? So I think many employees, unless you're working for a large firm that isn't self-funded, that has a lot of choice of insurance products, many, unfortunately, many employees, whether you're choosing between a small company or a large company, and a self-insured or, you know, self-funded or fully-insured products, there's less and less choice. Finally, on the self-insured part, our self-insured plans subject to regulations or requirements that are under the Affordable Care Act. Yes, some. And this is where, you know, the good news is that the Affordable Care Act was federal regulation, and so therefore, they were able to, in some ways, do more around self-funding funded plans than insurance, because insurance is primarily regulated by the states, right? But it's not, you know, we'd have to get into the weeds of specifics, right? What kind of a protection are we talking about, right? What kind of a plan or a benefit are we concerned about? Does that mean they went through with, you know, a list and they're like, the Affordable Care Act will preserve these things, but not these things? Or does it just get way too complicated to... I mean, I feel like it gets way too complicated because it's like, if they could, they did, but then there was also negotiation, right? So one of the ways that I think about this is it was a monumental thing to have the Affordable Care Act pass, monumental, right? Sometimes over, you know, decades, right, to have, I mean, we went from reform in the 60s when we got Medicaid and Medicare, right? And then multiple failed attempts by, you know, the Clinton administration, right? And like, so 2010, we get federal legislation around health insurance and health care and preventive care, right? So for that to happen involved a tremendous number of, right, give and take and agreements. And so when you read through the provisions, it's like, in this case, it doesn't apply to grandfather, you know, grandfather plans in this case, right? I mean, it looks like something that was built by, you know, a group desperately trying to get something passed, which is why like self-funded plans are something that's used for like religious organizations. So one of the benefits from an employer perspective, from the, you know, the payer of the claims is if you're self-funding, you don't have to follow the rules of insurance, including covering mandated benefits. So for example, in Wisconsin, there is a list, a legislative list, right? In our statutes, all the things that insurance companies that do business in Wisconsin have to cover. And so there may be things on that list that a religious organization would prefer not to cover. And so if they sell fun, then they don't have to cover those things. So I guess, is there anything else on self-funded plans that you want to go over before going specifically into a cumulative maximizer? Is there anything that like you've been thinking about since I've been asking these questions? I could see when you're doing your B-roll that I don't 100% agree with this chart, but like that I found this like incredibly helpful to just have people understand the why companies would choose self-funded, right? I mean, it literally says right here, direct savings opportunity, right? Like on the self-funded side, right? They're basically saying like the majority of your costs, right? You pay your for administration, which is to pay your third party administration, third party administrator. You pay for your stop loss, extra insurance, and then look at all your paying and claims. If you pay even 10% less of the claims, right, if you deny 10% of the claims, right, that's money in your pocket, right? And this is where you can see when you talked about religious organizations that when it's a fully insured product, there's cost to having to cover those required benefits, right? So part of what can, we could just argue that literally a self-funded plan can save money by not covering the required benefits, right? There's your 10% right there.