Key Findings
- 01"In-network" defines a ceiling on provider charges, not a floor on fairness — 34% of in-network claims exceed 200% of Medicare for routine procedures
- 02For a $10M annual health spend, this translates to $2M–$4M in recoverable overpayment that appears as legitimate in-network claims
- 03The problem is structural: carriers negotiate discounts off chargemaster rates, not benchmarks tied to the actual cost of care
- 04Benchmark-based auditing — comparing claims to Medicare rates, not to PPO discount percentages — is the only way to detect this pattern
Every year, your benefits team opens renewal with a carrier that leads with one number: the discount percentage. "We negotiated 45% off charges." "Our network delivers 52% discounts." The implication is clear — a bigger discount means a better deal.
It doesn't.
The discount percentage is calculated off the provider's chargemaster rate — an arbitrary, inflated list price that has no relationship to the actual cost of care. A 52% discount off a $2,000 chargemaster rate produces a $960 payment. The same procedure, done with identical skill at an independent facility, costs $280. The employer's plan paid $960 and called it "in-network" — and the carrier's metric shows a 52% discount as evidence of a good deal.
This is how 34% of in-network claims end up priced above 200% of Medicare, despite being "negotiated."
The Problem
Price transparency regulation has made it possible, for the first time, to see what carriers actually pay hospitals and health systems — not the discount percentage they advertise, but the dollar amounts on individual procedure codes.
When you compare those negotiated rates to Medicare rates for the same procedures, a consistent pattern emerges: most in-network rates for hospital-based services are high multiples of what Medicare pays. This isn't inherently wrong — Medicare rates are set by Congress, not by the market. But Medicare 2x (200% of Medicare) has emerged as the widely accepted benchmark for what a fair, well-negotiated rate looks like for commercially covered care.
By that standard, 34% of in-network hospital outpatient claims in our MRF analysis exceed 200% of Medicare. These aren't edge cases or exotic procedures. They're routine surgical assists, imaging studies, physical therapy episodes, and office-based infusion services — common claims, systematically overpriced.
What Our Data Shows
Our analysis of MRF data across major employer markets shows the following distribution of in-network negotiated rates relative to Medicare, for hospital outpatient services:
- Below 150% of Medicare: 18% of claims
- 150%–200% of Medicare (fair market range): 48% of claims
- 200%–300% of Medicare: 23% of claims
- Above 300% of Medicare: 11% of claims
The 34% of claims above 200% Medicare are concentrated in specific categories: hospital outpatient surgery, hospital-based imaging, and outpatient infusion. These are also the highest-dollar categories — the concentration of overpayment is not random.
For context, the RAND Corporation's annual study of employer-paid hospital rates shows that employers nationally pay an average of 254% of Medicare for hospital services — well above the 200% benchmark. Self-insured employers with smaller plans and weaker negotiating leverage typically fare worse.
The Cost to Employers
A $10 million annual health spend plan is not unusual for a mid-market employer. Of that $10 million, roughly 40% — $4 million — flows through hospital outpatient facilities. If 34% of those claims are priced above 200% of Medicare, and the excess averages 80% above the fair benchmark, the plan is carrying $1–1.5 million in recoverable overpayment in that category alone.
Across a full plan (including professional claims and other categories), the total recoverable amount for a $10M spend plan typically ranges from $2M–$4M annually — not through fraud detection, but through benchmark-based repricing and contract renegotiation.
This is money the plan is paying today. It's in your claims run. It looks like legitimate in-network utilization because it is — the overpayment is in the rate, not the utilization pattern.
What Smart Employers Do About It
Stop evaluating carrier performance by discount percentage. Ask your carrier or TPA to show you claims-level rates as a multiple of Medicare for your top 50 procedures by dollar volume. This single exercise shifts the conversation from "what discount did we get" to "what are we actually paying."
Benchmark your top 20 DRGs against Medicare. Your TPA can produce this report. For each of your 20 highest-dollar DRGs, calculate the average paid amount as a percentage of Medicare. Any category above 250% of Medicare is a candidate for renegotiation or center-of-excellence redirection.
Understand your plan's contract structure. Most large carrier contracts are "percent of billed charges" — the discount-off-chargemaster model described above. The alternative is a "percent of Medicare" or "reference-based" contract structure, where rates are tied to a stable, externally verifiable benchmark. Ask your broker to show you what a Medicare-anchored contract would cost your plan.
Commission a benchmark audit before your next renewal. A third-party audit that compares your actual claims against market rates — using Medicare multiples, not carrier discount percentages — will show you exactly where your plan is overpaying. This analysis typically takes 4-6 weeks and should be initiated at least 6 months before renewal to give you negotiating leverage.
The in-network designation exists to ensure employees have access to providers without surprise bills. It was never designed as a quality certification or a pricing guarantee. Employers who understand this distinction — and audit accordingly — consistently outperform those who don't.
"A 50% discount off an inflated chargemaster rate is not a 50% discount on what care should cost. Understanding this difference is the first step toward controlling healthcare spend."
See how these findings apply to your plan.
We run this analysis on actual claims data for self-insured employers. Your dedicated partner delivers these insights every month.