ERISA · CAA 2021 · Health Plan Governance

You manage your 401(k) like a fiduciary. What about your health plan?

Your organization may spend millions of dollars every year on employee healthcare.

The question is not simply whether you are offering competitive benefits.

Can you demonstrate a prudent process for how plan dollars are spent, vendors are selected, compensation is evaluated and important decisions are made?

Schedule a 20-Minute Conversation

Determine whether a Benefits Optimization makes sense for your organization.

Your 401(k) has a fiduciary process. Does your health plan?

Retirement Plan

  • Investment committee
  • Fee benchmarking
  • Advisor oversight
  • Investment monitoring
  • Documented meetings
  • Fiduciary governance

Health Plan

  • Who is responsible for fiduciary oversight?
  • How are broker and vendor fees evaluated?
  • How are PBM and carrier arrangements reviewed?
  • What plan data is available to decision-makers?
  • How are alternatives evaluated?
  • Where are important decisions documented?

Healthcare may be one of your company's largest operating expenses. The governance surrounding it deserves the same level of attention.

What if someone asked tomorrow:

“Show us your health plan fiduciary process.”

Could your organization quickly demonstrate:

  • Who is responsible for plan oversight?
  • What your broker and other service providers are paid?
  • Whether fees have been evaluated for reasonableness?
  • How major vendors were selected and monitored?
  • What alternatives were considered?
  • What claims, cost, quality and utilization data were reviewed?
  • What actions were taken to address unnecessary spending?
  • Why important plan decisions were made?
  • Where the supporting documentation is maintained?

If answering those questions means searching through emails, contracts, renewal presentations and shared drives, there may be an opportunity to strengthen your process.

Why CAA 2021 matters

CAA 2021 changed the benefits conversation.

ERISA fiduciary responsibilities for health and welfare plans existed long before CAA 2021. What changed is the level of transparency, disclosure and data access now expected around employer-sponsored health plans, and the importance of being able to demonstrate prudent oversight.

Transparency

Employers have greater visibility expectations around healthcare costs, arrangements and plan information.

Compensation

Plan fiduciaries should understand direct and indirect compensation paid to brokers, consultants and other covered service providers.

Data

Employers increasingly need access to meaningful plan information to evaluate cost, performance and vendor relationships.

Governance

Organizations should be able to demonstrate a prudent and repeatable process behind important plan decisions.

Benefits governance is a finance and enterprise-risk issue, not simply an HR renewal exercise.

Fiduciary governance is not just about compliance.

It is also about how your healthcare dollars are being spent.

Many of the same questions behind good fiduciary oversight tend to uncover financial opportunities.

  • Is broker compensation reasonable?
  • Are vendor fees transparent?
  • Are pharmacy economics aligned with the employer?
  • Are contracts competitive?
  • Is the funding structure appropriate?
  • Is the organization receiving the data it needs?
  • Are there avoidable costs or inefficiencies?
  • Has the market been meaningfully evaluated?
  • Are important decisions supported by objective analysis?

That is why we start with an Benefits Optimization.

The diagnostic

Don't start with another broker proposal. Start with the data.

The Benefits Optimization evaluates your existing benefits program before anyone recommends a change. It is an executive diagnostic, not an insurance quote.

What you are spending.
Where potential inefficiencies exist.
How your current program compares with alternatives.
Whether compensation and vendor arrangements deserve additional review.
Where additional fiduciary governance or documentation may be appropriate.
What opportunities are significant enough to act on.

01

Discover

A 20-minute executive conversation to understand the current benefits structure and determine whether a Benefits Optimization is appropriate.

02

Analyze

Review available plan, cost, vendor, compensation and market data.

03

Optimize

Identify financial, strategic and governance opportunities.

04

Execute

If meaningful opportunities exist, develop an implementation path with leadership.

Completing a Benefits Optimization does not mean changing brokers, carriers or vendors. The credibility comes from diagnosing before prescribing.

Schedule a 20-Minute Conversation

Determine whether a Benefits Optimization makes sense for your organization.

Five questions every benefits plan sponsor should be able to answer.

  1. 1

    What are we actually paying?

    Including premiums, administrative fees, pharmacy economics, broker and consultant compensation and other material plan expenses.

  2. 2

    Are those costs reasonable?

    What objective process have we used to determine that?

  3. 3

    Can we access the data necessary to evaluate our plan?

    Claims, cost, utilization and vendor performance information in a usable form.

  4. 4

    Can we demonstrate why we selected and retained our major benefits vendors?

    Including the alternatives that were considered at the time.

  5. 5

    Can we produce documentation supporting our decision-making process?

    Organized, current and available if someone asks for it.

If leadership cannot confidently answer all five, the next step is not necessarily changing anything. It is understanding where you stand.

Benefits governance

When governance gaps are identified, they can be organized into a process.

Where a Benefits Optimization identifies documentation or oversight gaps, employers can be supported with an organized fiduciary governance process as part of a broader benefits strategy.

Identification of fiduciary roles and responsibilities
Centralized plan documentation
Compliance activity tracking
Service-provider compensation review
Vendor oversight documentation
Fiduciary meeting and decision records
Governance calendars
Action-item tracking
Ongoing fiduciary documentation
Preparation and organization of a fiduciary file

This page is provided for general informational purposes and does not constitute legal advice. Employers should consult qualified legal counsel regarding their specific fiduciary and compliance obligations.

You don't need another benefits pitch.

You need to know whether there is anything worth fixing.

The Benefits Optimization starts with your current program, your data and your economics.

If the analysis identifies meaningful financial, strategic or fiduciary opportunities, we will show you what they are and what an execution path could look like. If it does not, you will know that too.

No cost. No obligation. Determine whether a Benefits Optimization makes sense for your organization.