CFO & FINANCE LEADERS

Your corporate health plan spend is now a major litigation risk.

Health benefit spend has been managed as a budget line, not a
governed asset. Closing that gap protects the P&L on both fronts.

01

The spend is
accelerating.

The Milliman Medical Index shows family healthcare cost up 7.9% year over year,
the steepest rise in over a decade outside the pandemic¹².

7.9%

GROWTH IN FAMILY HEALTHCARE COSTS¹²

20%

MANDATORY DOL PENALTY

OF THE AMOUNT RECOVERED

6

IN CUMULATIVE PENALTIES CAN BE ASSESSED

YEARS

02

Litigation exposure
is real money.

A single ERISA settlement can exceed tens of millions once legal
defense, damages, and mandatory DOL penalties of 20% of the
amount recovered stack up against shrinking fiduciary coverage.¹⁴

03

Your window to act is closing.

CAA 2026’s full rebate pass-through arrives August 2028⁹, but disclosure obligations exposing current rebate leakage land within 6–18 months¹⁰. A fiduciary who has the data and does nothing is worse off than one who never had it.

Disclosure window opens

NOW

6-18 MONTHS

Current rebate leakage

AUGUST 2028

Full rebate pass-through

FROM BLACK BOX TO GOVERNED ASSET

Fiduciary Frameworks turns
PBM and vendor spend from
an unaudited black box into a
governed, documented process.