How should an employer prepare for a DOL health plan audit?
Last updated October 2, 2026
Prepare before the letter arrives. Maintain a complete, organized fiduciary file — plan documents, SPDs, Form 5500s, committee minutes, vendor agreements, fee disclosures, and CAA compliance evidence — engage ERISA counsel early, and respond through a single coordinator. Audit readiness is a byproduct of good ongoing governance, not a last-minute project.
A Department of Labor investigation typically opens with a document request letter from the Employee Benefits Security Administration (EBSA) listing dozens of items with a response deadline. Employers who manage health plan compliance well experience this as an assembly exercise; employers who don't experience it as a crisis.
Preparation that works happens in two phases:
- Before any audit: keep a current fiduciary file (see the organizing-your-files question in this topic), hold and document regular committee meetings, complete required filings on time, and fix known gaps — late Form 5500s, missing SPDs, unsigned charters — through correction programs rather than hoping they go unnoticed.
- When the letter arrives: notify ERISA counsel before responding, designate one coordinator for all DOL contact, calendar the deadline and request extensions early if needed, and produce exactly what is asked — complete, organized, and on time.
EBSA recovers well over a billion dollars for plans and participants in a typical year, and health and welfare plans are an active enforcement priority under the Consolidated Appropriations Act. The employers who fare best are those whose documentation already tells a story of a managed, deliberate process.
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