The era of passive plan oversight is over. Schlichter's 4-suit December 2025 dump, the Supreme Court's Cunningham decision, the Sixth Circuit's Tiara Yachts ruling, and the CAA 2026 PBM reforms together create a perfect storm of fiduciary risk. Here's what every self-funded plan fiduciary must know.

Every year, self-funded health plan fiduciaries are handed a legal contradiction. ERISA holds them personally liable for billions in plan assets. Yet the TPAs who actually pay those claims routinely deny access to the data required to validate that spending. A fiduciary cannot prudently oversee what it cannot see.

The January 2026 issue of The Self-Insurer makes one thing clear: 'fiduciary' is no longer a formality buried in plan documents — it's a market force reshaping vendor relationships, compressing margins, and raising expectations for transparency and performance.

On December 23, 2025, Schlichter Bogard LLC — the firm that extracted billions from 401(k) plan fiduciaries — filed four simultaneous ERISA class actions targeting major employers and their benefits consultants. The 401(k) playbook is now targeting healthcare benefits.

The BUCA pre-pay editing 'advantage'? Largely a myth. BUCA carriers built their editing engines to protect their fully insured book — not yours. Independent TPAs are sitting on the single most powerful differentiator in the market — and most haven't deployed it yet.

$1.4 billion recovered. 878 investigations closed. And that was just the warm-up. On January 15, 2026, the DOL announced a wholesale shift of enforcement resources directly toward self-funded health plans, TPAs, and the fiduciaries who oversee them.

Your TPA's dashboard shows you what was paid. It doesn't show you whether it was paid correctly. Stephen Carrabba joins the PLANSPONSOR Roadmap 2026 Livestream Series to walk plan sponsors through the questions carriers would prefer they didn't ask.

Michael Riemer has been appointed Chief Operating Officer at ClaimInformatics, following a ten-month engagement that delivered nearly $1M in annual operating efficiencies, a redesigned claim review engine, generative AI deployment, and the launch of CLEAR™.

The voluntary benefits lawsuits weren't about accident insurance. They were about the process. The same procedural prudence framework is now being applied to healthcare benefits.

A nonprofit prevailed against the DOL in one of the first health plan excessive-fee cases. Here's exactly how they did it, and why it matters for every self-funded plan fiduciary in 2026.

Benefit consultants and brokers face fiduciary liability after Schlichter names Gallagher, Mercer, Lockton, and WTW in ERISA suits. The 401(k) playbook has come to healthcare consulting.

Between 2010 and 2024, the number of registered broker-dealers dropped by 30%. The same regulatory pattern is now coming for benefits brokers, and the early-adopter advantage is real.