Author: Tia Goss Sawhney

Health Plan Bill Reviews are not Audits
and are Required to Fulfill Fiduciary Duties

July 25, 2025
Tia Goss Sawhney
Many people in the healthcare payment industry often conflate and sometimes misuse the terms “audit” and “bill review” and/or “claims review.” In reality, these terms refer to two separate and distinct processes with different rules and considerations. While audits may be subject to specific contractual requirements, self-funded plan sponsors have an affirmative responsibility and duty to review their claims data prior to payment in light of ERISA’s mandatory fiduciary duties.