Why Fiduciary Responsibility in Health Benefits Can’t Be Ignored in 2025
Over the past few years, employers have become increasingly aware of their fiduciary responsibilities when it comes to managing 401(k) plans. But a lesser-known—and equally important—fiduciary duty is now drawing attention: your role as a fiduciary of your company’s health plan.
With health care costs rising, new federal transparency regulations taking hold, and lawsuits against plan sponsors making headlines, employers can no longer afford to be passive in their oversight. If you sponsor a group health plan, you are a fiduciary under ERISA, and that comes with legal and financial obligations.
Here’s what you need to know, and what you should be doing now.
What Does It Mean to Be a Fiduciary?
A fiduciary is someone who acts solely in the best interests of plan participants, with the duty to:
Make prudent decisions
Ensure plan costs are reasonable
Avoid conflicts of interest
Monitor vendors and plan performance
Document processes and decisions
This responsibility doesn’t just apply to retirement plans. Employer-sponsored health plans are also covered under ERISA, and failing to meet fiduciary standards could open your organization up to serious risk.
The Transparency Rules That Changed Everything
The Consolidated Appropriations Act (CAA) of 2021 and federal price transparency rules are transforming how health plans must operate.
These regulations now require employers to:
Provide machine-readable files showing in-network and out-of-network rates
Offer cost comparison tools to employees
Monitor third-party administrator (TPA), carrier, and PBM relationships for conflicts or excessive fees
This isn't just a compliance checkbox…it’s a shift in accountability. The Department of Labor is already increasing enforcement, and employees are starting to ask hard questions about plan value.
Why Fiduciary Responsibility is a Hot Topic in 2025
In today’s benefits landscape, employers are under pressure from all sides:
Medical and Rx costs are rising fast—especially due to GLP-1 drugs and specialty medications
New lawsuits are targeting employers for overpaying vendors or failing to monitor PBMs
Employees expect more transparency and equitable access to care
Audits are increasing, and many employers don’t realize they’re out of compliance
Health plans are now a strategic business asset…and a liability if mismanaged. A well-managed plan can drive employee satisfaction, reduce absenteeism, and support long-term organizational goals. But if mismanaged, it can quickly become a financial drain, expose the company to regulatory penalties, and damage employee trust.
Your Fiduciary Responsibilities as a Plan Sponsor
If you offer a group health plan, here are some key duties you’re expected to fulfill:
Select and monitor vendors prudently
While we certainly have your best interest in mind, you can’t always assume your broker or carrier does—so evaluate performance regularly.Ensure fees are reasonable
This applies to carriers, TPAs, PBMs, and any other entity that profits from your plan.Avoid conflicts of interest
Understand how your partners are compensated and whether their incentives align with your employees’ needs.Keep records of your decisions
Document why you chose a vendor, how you evaluated their fees, and what steps you’re taking to improve their performance.Act in your employees’ best interest
Every decision should serve your plan participants—not just your budget or internal goals.
What Employers Should Do Now
Here are 5 action items you can do right now to reignite your fiduciary responsibility.
Review your vendor contracts
Look for hidden fees, lack of transparency, or rebate arrangements that favor the vendor—not your employees.
Benchmark plan costs and utilization
Use third-party data from trusted sources to compare your plan performance against national or regional averages.Ask the tough questions
How does your PBM make money? Are your broker commissions disclosed? Who owns the data?Get certified or work with fiduciary-aligned partners
Research training programs for yourself or hire specialized consultants who can help guide your compliance and protect your business.Create a governance process
Set up regular reviews, audits, and documentation systems for yourself and your team to support your fiduciary decisions.
Protect Your People, and Your Business
It’s no longer enough to simply offer a health plan. As an employer, you are a steward of your employees’ health care dollars. Embracing your fiduciary responsibility isn’t just a legal obligation, it’s a powerful opportunity to create a more efficient, equitable, and transparent health plan.
By taking proactive steps now, you can protect your company from regulatory risk, improve outcomes for your workforce, and strengthen your reputation as a responsible employer.
We Know This Isn’t Easy—And You Don’t Have to Navigate It Alone
We get it! Fiduciary responsibility in health benefits isn’t exactly light reading. It’s complex, it’s evolving, and it can feel overwhelming on top of everything else you’re managing as an employer. But you’re not expected to be the expert in all of this—that’s where we come in!
At Caravus, three of our Employee Benefits Advisors are certified Behavioral Governance Institute Healthcare Fiduciary Coaches. They are equipped with specialized training to help employers and HR professionals navigate their healthcare fiduciary responsibilities with clarity and confidence.
Whether you need a clearer understanding of your responsibilities, help evaluating your vendor contracts, or just a sounding board to talk through your strategy, we’re ready to support you with guidance that’s both practical and personalized.