What documents does the DOL typically request in a health plan investigation?
Last updated October 2, 2026
EBSA document requests commonly cover plan documents and amendments, SPDs and SMMs, Form 5500 filings, committee minutes, service provider agreements, broker compensation disclosures, the fidelity bond, claims and appeals records, HIPAA documentation, and CAA compliance evidence like gag clause attestations and RxDC submissions.
While every investigation differs, EBSA request letters for group health plans draw from a consistent core list:
- Plan documents, wrap documents, amendments, and the Section 125 cafeteria plan document
- SPDs, summaries of material modifications, and evidence of distribution to participants
- Form 5500 filings and Summary Annual Reports
- Fiduciary committee charters, appointment records, and meeting minutes
- Service provider agreements, broker and consultant compensation disclosures under ERISA Section 408(b)(2)(B), and vendor selection records
- The ERISA fidelity bond
- Claims procedures, denied claims, and appeals files
- CAA compliance evidence: gag clause attestations, RxDC reporting confirmations, machine-readable file postings, and the NQTL comparative analysis
Reading that list is the best argument for maintaining a standing fiduciary file. Every item on it is something the plan should already have — the only question an audit really asks is whether you can find it.
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