HR LEADERS

You're the plan fiduciary. Make sure you can defend your choices.

The carrier, broker, and PBM calls you’re making this cycle
are the exact decisions now being litigated. Document your
process before it’s tested.

01

The decisions in litigation are HR decisions.

Suits against employers like
United Airlines and LabCorp concern voluntary products packaged with corporate health plans¹ᵇ ¹ᶜ

22%-40%

Product commissions
alleged at

of premiums ¹ᵇ ¹ᶜ

NOW

YOU MUST ACT

02

Disclosure obligations
are arriving fast.

And there is an important fiduciary consequence: getting a disclosure isn't the end of the process. An ERISA fiduciary ultimately has to use the information in a prudent process to evaluate whether the arrangement and compensation are reasonable.

03

Cost pressure
raises the stakes.

Pharmacy costs rose approximately 9.4% in 2025⁴ and are
forecast to grow 11%–12% in 2026¹¹, putting more dollars behind
the same decisions now under scrutiny.

2026

11% - 12%

9.4%

2025

FROM DISCLOSURE TO DOCUMENTATION

New data is becoming available across the healthcare marketplace. Fiduciary Frameworks helps you turn it into a defensible fiduciary process, documented oversight, and better outcomes.