RFP Analysis: What’s changed for FSAs, HRAs, and HSAs?

Learn how request for proposals for FSAs, HRAs, & HSAs have changed over time.

When technology changes, so do our expectations. (Nobody asks for your AIM screen name* anymore.) And we see this evolution in expectations in request for proposal (RFP) questions; they don't ask 'em like they used to.

We wanted to know how RFP questions have changed, so we compiled a list, sorted them into two groups (current and past), and analyzed for trends. Our analysis revealed dramatic shifts: where RFPs once asked about monthly report delivery, they now demand drill-down analytics for dashboards. The evolution spans flexible spending accounts (FSAs), health reimbursement arrangements (HRAs), and health savings accounts (HSAs)—and it happened faster than you might expect.

*Hossball

Free template

Based on our analysis, we created a free resource with example questions you might see on an RFP. To diagnose your organization's readiness, download our 2025 RFP Template.

Acronym and glossary list

Here are some acronyms and words that will be helpful to know:

  • CDH: consumer-directed health (which captures FSAs, HRAs, and HSAs)
  • FSA: flexible spending account
  • HRA: health reimbursement arrangement
  • HSA: health savings account
  • participant: account holder, consumer, employee, member—the person who uses the benefit
  • KYC: know your customer
  • RFP: request for proposal
  • SLA: service level agreement

Method of research

Here’s how we conducted our research.

Sample size

We analyzed FSA, HRA, and HSA RFPs from two different periods: 2013-2021 and 2024-2025. While our sample set provides valuable directional insights, it’s not comprehensive enough to support definitive industry-wide conclusions. We treated these findings as conversation starters, validating them with industry subject matter experts who confirmed: “Yes, this aligns with what we’re seeing.” Our goal for the article is that it does the same for you and your team—helps you assess whether your current technology stack is ready for these emerging trends.

Card trends

For most participants, the arrival of a debit card in the mail marks the start of a new benefit. With proper card guardrails, cardholders can access their funds for eligible expenses with minimal administrative effort. Every substantiated card transaction is one less claim for admin review.

Then: Do you have a card?

Does your organization offer debit cards to program participants?

2020 FSA and HSA RFP

Past questions focused on mere existence, such as, "Do you offer a debit card?" RFPs treated debit cards like a yes/no question, like something to check off a list. That's no longer the case.

Now: Do you have a card for everything?

Explain how your single-card feature manages multiple benefits.

2024 CDH RFP

In 2025, the focus has shifted from “Do you have a card?” to “Do you have a card that can manage multiple benefits?” And everyone’s searching for the right words to describe this type of card. In our research, we came across “debit card for both accounts,” “single card support,” and “multi-product payment cards.”

Virtual and international  

We also noticed an increase in recent requests for virtual cards and the ability for cardholders to use their cards abroad.

Cards trend recap

About Virtual Cards

To learn about First Dollar’s virtual card product, check out our product release.

HSA investing trends

With an HSA, participants can make tax-free investments for tax-free growth. And since the average retired couple will need $351,000 for healthcare expenses, it’s no surprise that HSA investing was a popular topic in RFP requirements.

Then: What’s the name of the third-party website for HSA investing?

What web functionality is available to support HSA investments? If investments are part of a third-party site, please specify who administers the site.

2015 FSA & HSA RFP

Past RFPs made two main assumptions: HSA investing would occur on a website, and another party would run that website. The RFPs just wanted to know who would be running that third-party website.

Now: What are your platform investing features?

Detail how your platform supports program members buying, selling, and viewing their HSA investments.

2024 HSA RFP

Today's brokers want to know which HSA investment activities can occur on the platform; embedded HSA investing is the assumption. We also see higher expectations for the investment menu, with increased inquiries about fractional shares, automatic investing, and robo-advisor capabilities.

Investment recap

About embedded investing

To learn about First Dollar’s embedded investing for HSAs, available on our web portal and our app for participants, check out our product release.

Reporting trends

With good reporting tools, teams can quickly understand organization performance for service level agreement (SLA) target metrics, like know your customer (KYC) processing and claims adjudication.

Then: Who do we contact for new reports?

Describe the access we’ll have to an ad-hoc reporting liaison.

2015 FSA RFP

Now: What reporting can we do on our own?

Share a list of the available self-service reporting tools that will be provided to teams.

2025 RFP

Today, RFPs prioritize reporting tools over reporting support. We saw mentions of "interactive dashboards," "self-service capabilities," and "customizable visualizations." And we no longer see questions like "Can you provide monthly reports?" This new focus reflects a shift from vendor-controlled reporting with static reports to client-controlled reporting with self-service tools and interactive, customizable dashboards.

Industry Context

Employee usage of business intelligence and analytics is increasing. Data and analytics leaders attribute this to a rise in self-service authoring tools (73%) and embedded analytics (38%).

Reporting recap

About reporting

To learn about First Dollar’s reporting tools, check out our product release for our reporting API.

Education trends

Since day one, most industries have agreed that providing educational resources is important. And that's even more true today, as only 68% of plan participants report using all of their available benefits.  

Then: What brochures will you provide?

Provide sample enrollment guides and welcome brochures

2020 RFP

Now: What learning opportunities will you provide to participants in their language?

List all educational resources you will provide members. Include learning modules and apps.

2025 RFP

The new RFP focus shifts from print materials to targeted, interactive learning experiences. For example, we saw requests for apps, calculators, and learning modules. We also came across requests for multi-language support.

Learning context

Interactive learning can increase student focus, engagement, and overall learning performance.

Education recap

AI trends

Everyone’s talking about AI, and the RFPs are as well. We’re excited to see how AI tools will continue to evolve to meet industry needs, like claims submission and consumer education.

Then: What’s AI?

As you likely expected, there were no RFP questions about AI tools before 2025.

Now: Name your AI-powered features.

Describe AI-powered tools that help improve claims substantiation.

2025 RFP

Artificial intelligence is here, and RFPs are asking vendors to spell out their AI-driven features. We saw RFP queries about AI-driven tools for automated receipt scanning and claims adjudication. Soon, we anticipate seeing more questions for AI-driven tools for CDH pain points like fraud detection, customer support, predictive analytics, and more.

Market Context

According to McKinsey's 2025 State of AI report, 71% of respondents say their organizations regularly use generative AI.

AI future deep dive: Name your non-AI features

Future RFPs will ask which features are NOT driven by AI.

As the market adapts, AI will evolve from dominating conversation to dominating product. Reflecting this trend, RFPs will move from asking vendors for a list of AI-powered features to asking for features not powered by AI.

Tomorrow's winners will not only have AI-powered features but also the platform flexibility to evolve with new technology and regulation. When new capabilities emerge, the platform needs to adapt quickly, with no lengthy development cycles.

AI will automate the routine stuff—receipt scanning, basic claims processing, and simple questions. But benefits administration still needs human judgment for complex cases, strategic decisions, and relationships. We are in a business that ultimately services people, and we must keep that perspective amidst the adoption of AI.  

The question will not be whether an organization has AI. It will be whether it balances AI efficiency with human expertise that counts.

AI recap

Trends recap

Here is a recap of the trends we noticed in the RFPs.

It’s about people

What’s behind these trends? At the end of the day, benefit RFPs reflect the needs of the people who use them.  

Today’s consumer behavior  

Over nine in ten U.S. adults own a smartphone, and they use it. Over eight in ten use a financial app, while one in two use a digital wallet. And let's not forget consumer adoption of AI. Chat GPT broke all consumer app records when it reached 100 million monthly active users (MAUs) within two months of launch.

Past focus on price

Past RFPs for consumer-directed health benefits like FSAs and HSAs focused on minimal noise and the lowest price. The technology was considered the same, as the same platform vendors power two/thirds of the marketplace, so the only way for organizations like third-party administrators (TPAs) to stand out in the bidding process was to have the lowest price.  

Focus on tech

The trends reflect a growing need for benefits to catch up to consumer trends. Technology is no longer buried, and assumptions are no longer being made about what is possible. Bid applicants can stand out (and win) with better tech.

Next steps

To access more 2025 RFP questions, check out The New RFP: A FSA, HRA, & HSA Template for 2025.

Josh Hostetler

Josh leads content for First Dollar. Before First Dollar, Josh led writing teams building regulated education courses at Aceable, taught First Grade, waited tables at Olive Garden, and wore many other hats. He misses the breadsticks.