What is the Fiduciary Forum?

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A trusted space for employer-led oversight, built on experience, fueled by collaboration.

Understanding CAA 2021’s Compensation Rules

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With renewal season in full swing, employers should be actively requesting and reviewing compensation disclosures from all Covered Service Providers. Are you receiving them? How successful have you been in getting clear, complete disclosures? And once received, how are you evaluating whether they’re compliant with CAA 2021 requirements? This is a critical—yet often overlooked—step in your fiduciary process. We invite employers to share their experiences, challenges, and tips. To support you, here’s a link to a few articles that include language you can adapt to make your requests more effective.

links to the articles

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https://www.napa-net.org/news/2025/8/how-employers-can-build-document-defensible-health-plan-fiduciary-processes/ https://www.napa-net.org/news/2025/8/if-you-sponsor-a-health-plan-youre-a-fiduciary--whether-you-realize-it-or-not/ https://www.napa-net.org/news/2025/8/health-plan-compliance-what-employer-fiduciaries-must-know/

Starting a Fiduciary Committee for your health plan

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Love to know how your organization got started. As fiduciary responsibilities expand under the CAA 2021, many employers are realizing the importance of creating a formal Fiduciary Committee to oversee their health benefits plan. This committee should include the decision makers on the health care plan. Here’s a quick checklist of who might belong at the table: • HR Leader (plan design & compliance) • Finance or Accounting Pro (budgeting & cost oversight) • Legal Counsel (regulatory and contract review) • Plan Administrator (day-to-day ops) • Senior Executive (strategic alignment) Optional: Employee Reps & external experts (transparency + insight) A well-structured committee should also have a mission statement. This committee is your front line of defense against risk and noncompliance. Don’t forget to have fiduciary liability insurance on the committee as well.