Blue Cross Blue Shield (BCBS) Uninsured (ASO) Fees Analysis 2021-2025
July 9, 2026
Blue Cross and Blue Shield (BCBS) entities and their affiliates reported receiving $23.6 billion in reimbursements in 2025 from uninsured plans, a 26.6% hike from the $18.7 billion reported in 2021. Reimbursement from uninsured plans is more commonly known as administrative fees from self-insured accounts. Understanding the amounts of administrative fees collected by insurers for self-insured business is often a mystery for analysts studying this sector of the health insurance industry. After analyzing the multiple sources of administrative fees found in statutory filings from the National Association of Insurance Commissioners (NAIC), available in Mark Farrah Associates’ (MFA’s) Health Coverage Portal™, MFA found consistency in assessing this data over time.
As previously reported* health insurance companies in 2025 provided fully insured coverage for over 183 million people. Additionally, an estimated 135.5 million people received health coverage from an employer or other sponsor that self-insures most medical expenses. These sponsors contract with an insurance company or independent third-party administrator (TPA) for plan administration and pay fees for these services. The NAIC refers to the coverage offered by a self-insured sponsor as an uninsured plan and the administrative fees collected by an insurance company from these plans as reimbursements or fees or income from uninsured plans. These services, provided by a TPA or traditional insurer, are often done under an administrative services only (ASO) agreement or an administrative services contract (ASC). Most traditional insurance companies report fees collected through uninsured plans in three locations in their statutory filings with the NAIC. While assessing data on BCBS organizations and their affiliates (referred to collectively as Blues), MFA analyzed the five-year period between 2021 and 2025 for Blues performance in the ASO/ASC segment.
MFA’s Blues analysis found that in addition to offering fully insured coverage, Blues organizations receive fees from uninsured plans that provide coverage for nearly 64 million people, 47% of the people receiving coverage through self-insured plans in 2025. In the last five years, these same companies increased self-insured enrollment by nearly 2.4 million people. Blues entities and their affiliates reported receiving $23.6 billion in reimbursements from uninsured plans in 2025, an increase of $5 billion from 2021. Elevance, Health Care Service Corporation (HCSC), Highmark, and BCBS of Michigan** (BCBS of MI) all collected over $1 billion in reimbursements by uninsured plans in 2025.
- Elevance Health, with Blues plans in 14 states, has the largest share of administrative fees collected by Blues entities at 31.6% for 2025. Despite increasing fees from $5.5 billion in 2021, to $7.5 billion in 2025, Elevance Health’s share of total Blues’ fees increased from 29.4% in 2021 to 31.6% in 2025.
- HCSC, which operates Blues plans in Illinois, Montana, New Mexico, Oklahoma, and Texas, reported the second most reimbursement for administrative fees of $4.2 billion in 2025.
- Highmark, with Blues plans in Pennsylvania, Delaware, West Virginia, and New York has the third highest share of fees at $1.3 billion.
- Capital Blue Cross, based in Pennsylvania; BCBS of New Jersey (Horizon); BCBS of North Carolina; Excellus BlueCross BlueShield (New York, parent Lifetime Healthcare, Inc.); and BCBS of Tennessee; were among the other Blues plans with significant gains in reimbursements for administrative fees in the last five years.
* MFA Healthcare Business Strategy Brief: Five-Year Enrollment Trends Comparing Blues & Non-Blues Health Plans, May 28, 2026.
** For consistency, BCBS of MI’s ASO fees for 2021 and 2022 include BCBS of Vermont, which became an affiliate in 2023.
About the Data
The data used in this analysis was obtained from Mark Farrah Associates' Health Coverage Portal™ database. Findings reflect reimbursements of uninsured fees reported by carriers with business in the U.S. and U.S. territories. Data sources used in the above report include statutory financial filings with the National Association of Insurance Commissioners (NAIC), including the Analysis of Expenses, Notes to the Financial Statements and Supplemental Health Care Exhibits. California (CA) based plans that file statutory reports with the California Department of Managed Health Care (CA DMHC), including Blue Shield of CA, do not file any exhibits with administrative fees and are excluded from the above results.
About Mark Farrah Associates (MFA)
Mark Farrah Associates (MFA) is a leading data aggregator and publisher providing health plan market data and analysis tools for the healthcare industry. Our product portfolio includes Health Coverage Portal™, County Health Coverage™, 5500 Employer Health plus, ASO Employer Health plus, Medicare Business Online™, Medicare Benefits Analyzer™, and Health Plans USA™. For more information about these products, refer to the product pages and brochures available under the Our Products section of the website (www.markfarrah.com) or call 724-338-4100.
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