Healthcare in Harmony – Fiduciary Compliance Through Payment Integrity

"You got boats. You got a second home. You got cars. All that's on the chopping block."

That's not a scare tactic. That's the reality of ERISA fiduciary liability for self-funded health plan sponsors — and it's exactly what Stephen Carrabba laid out at a recent industry event.

Fiduciary duty isn't abstract. It's personal. And most plan sponsors don't realize how much exposure sits in the gap between what their TPA says is happening and what's actually happening with their claims.

A few things worth understanding

Upcoding isn't always fraud — but it's always your problem. Proving intent is nearly impossible. What matters is whether improper payments happened on your watch and whether you had independent oversight to catch them.

Brokers aren't off the hook either. The Schlichter lawsuits named Aon, Lockton, Mercer, and Willis Towers Watson as co-defendants — not just plan sponsors. The argument: brokers also carry fiduciary obligations.

Oversight is the answer. Ensuring that plan documents are followed. Monitoring service providers independently. Documenting prudent process. That's what protects you.

Payment integrity isn't a line item. It's fiduciary compliance in action.

Are your service providers being independently reviewed — or are they auditing their own work?