Is fiduciary training required for health plan committee members?
Last updated October 2, 2026
ERISA doesn't explicitly mandate fiduciary training, but the Department of Labor expects fiduciaries to understand their duties, and courts treat untrained fiduciaries harshly. Documented annual training is the practical standard — it strengthens decisions and evidences prudence.
There is no statute that says "fiduciaries must attend training." But the prudence standard requires fiduciaries to act with the skill of someone familiar with plan matters — and a fiduciary who can't demonstrate basic knowledge of their duties has a hard time demonstrating prudence.
DOL investigators routinely ask what fiduciary training committee members have received, and litigation discovery does the same. A thin answer undermines every other defense.
The practical standard is simple: train every new committee member when appointed, refresh the full committee annually, and document it — dates, topics, attendees. The training itself doesn't need to be elaborate; consistent, documented coverage of duties, prohibited transactions, and the committee's own procedures is what counts.
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