“Too Much Information”: The Life Insurance Broker's Guide to Ordering Health Data in 2026
Ian Levinsky
As Sting and the Police put it in 1981: “Too much information running through my brain. Too much information driving me insane.”
If you order medical data for life insurance underwriting, the ground is moving. And if you’re new to it, there’s too much to figure out. New acronyms, lawsuits flying in every direction, and a dozen vendors all pitching "comprehensive EHR access" as if it's a complete replacement to retrieving an APS.
Over the last 6 months, I've been getting asked more and more for my perspective on third-party medical data. I'm honored to be asked, but if I properly self-assess, I haven’t been giving great answers.
Time to change that. Over the last 3 months, I've dug in with experts, asked a lot of questions, and built my own mental model on how this world works.
What I found also ended up shaping something we’re launching next week at Pathwork… more on that at the end of this post.
So if you're a broker who wants to gain an edge with medical data, here's what you need to know.
Start with the right foundation: Rx + medical claims
Before anyone gets excited about EHR, understand what the actual workhorse of underwriting looks like in 2026.
Prescription history pulled from PBMs, pharmacies, and claims clearinghouses sits at roughly a 90% median hit rate (LIMRA, 2022) and returns in seconds. The leading Rx databases span a 7-year lookback, refresh continuously, and reflect newly filled prescriptions in reports as soon as the next day.
Add adjudicated medical claims on top of Rx and you capture the providers EHR networks systematically miss: ER visits, mental-health clinics, substance-abuse and tobacco-cessation programs, and specialty providers who never adopted an EHR or never joined a Health Information Exchange (HIE). The leading medical claims source has successful hits on more than 80% of applicants and surfaces hundreds of structured clinical data points per person.
A joint study by RGA and the leading Rx/claims dats provider — covering 42 million applicants across 25 carriers — found that adding medical claims to Rx lifts straight-through processing from 56% to 71%.
EHR data: what it is, and where it sits today
EHR data is structured clinical information pulled directly from the systems your clients' doctors use — Epic, Oracle Health (formerly Cerner), athenahealth, eClinicalWorks, and others. It captures diagnoses without prescriptions, vitals, labs, problem lists, and free-text notes — exactly the data that lets carriers eliminate paramedical exams on fully underwritten cases.
The market has consolidated sharply over the last 24 months. There are effectively three commercial EHR-for-life vendors today:
MIB EHR, which acquired Clareto from Munich Re in May 2025.
LexisNexis Health Intelligence, built on the Human API acquisition closed in April 2023.
Health Gorilla, which is now a defendant in active federal litigation (more on that in a minute).
EHR data is improving, but at production hit rates of under 50%, with the comprehensiveness of a returned applicant profile actually coming in far lower than that, it's likely best to wait and see.
The permissible-use problem
Under TEFCA, you can't just pull a patient's records because you want them. You need a Permitted Purpose. There are six: Treatment, Individual Access Services, Payment, Health Care Operations, Public Health, and Government Benefits Determination.
Life insurance underwriting is not on that list.
The clean route for life is Individual Access Services — the patient requests their own records and authorizes them to be forwarded to the underwriter. It is HIPAA-authorized, traceable, and survives an audit. The major commercial EHR-for-life vendors operate on that authorization-only path, deliberately routing around TEFCA. One of them has publicly advocated for a dedicated life-insurance Exchange Purpose, which does not yet exist.
The shaky route is everything else. Some vendors have been creative — invoking "Treatment" via thin telehealth designations, then routing the resulting data into secondary commercial uses. That is what the litigation is now testing.
The market flashpoints
In January 2026, Epic sued Health Gorilla in the Central District of California. The plaintiffs allege that roughly 300,000 patient records were taken via false "Treatment" claims and monetized for mass-tort plaintiff recruitment by downstream clients, including GuardDog Telehealth. GuardDog admitted improper access and agreed to be barred from HIEs in March. Health Gorilla denies the broader allegations. The case is active.
That case is not about life insurance. But it raises the audit bar for every commercial use of HIE data — including any life-insurance pathway that touches Carequality or TEFCA under a "Treatment" or stretched-Benefits-Determination theory.
The three questions to ask any data vendor
What Permitted Purpose are you invoking when you pull this data? If they can't answer it in one sentence, that is your answer.
Are you a QHIN, a participant under a QHIN, or a downstream reseller — and who signs the BAA? Each layer has different obligations and very different exposure.
What's your chain of consent, and can you produce it on demand?
The cheapest path to data is rarely the one that survives the audit.
What's next from Pathwork
Next week we're announcing something we've been working on for a while — a new way for brokers to order Rx and medical claims data on demand, in seconds, before deciding where to submit a case.
It's powered by data used every day in modern formal underwriting and has been trusted for more than 20+ years. Rx with a 7-year lookback refreshed by the next day, medical claims on more than 80% of applicants, and hundreds of structured clinical data points per person — is in your hands before submission. Less guesswork. Reducing surprises. Accelerating your path to placement.
If you've felt the ground shifting and don't love where it's heading, keep an eye on this feed.
Sources:
LIMRA, "Chasing Amazon: Accelerated Underwriting Focuses on CX," Market Facts, 2022 Link
RGA's Actuarial Validation of Milliman Irix® Risk Score 3.0 Link
Milliman IntelliScript — RGA Actuarial Stamp of Approval on Irix Risk Score 3.0 Link
MIB press release: MIB acquires Clareto from Munich Re Life US (May 2025) Link
LexisNexis Risk Solutions — acquisition of Human API (April 25, 2023)
ONC — Data Liquidity, Affordability, and Access: The History & Growth of TEFCA Link
Legal HIE — "Unmasking the Issues: The Final Resolution in the Epic v. Particle Health Dispute" Link
GuardDog Telehealth admission / HIE bar (March 18, 2026)
LexisNexis Life Insurance Consumer Experience Study (released May 7, 2026)