What does prudent vendor selection and monitoring look like for a health plan?

Last updated October 2, 2026

Prudence means a documented process — defining needs, comparing candidates, evaluating fees and services, checking references — followed by ongoing monitoring through periodic performance reviews, fee benchmarking, and renewal-time reassessment. The file you build is the proof your process existed.

Hiring TPAs, brokers, PBMs, and carriers is a fiduciary act, and ERISA judges it by process. A defensible selection includes:

  • A written scope of the services needed
  • Comparison of multiple candidates (an RFP for major vendors; documented market checks for smaller ones)
  • Evaluation of fees — including the CAA-required compensation disclosures — against services
  • Reference and capability checks, memorialized in the file

Selection is half the duty; monitoring is the other half. Review vendor performance and total compensation at least annually, revisit the market periodically (every 3–5 years for major vendors is a common benchmark), and act on service failures. Committee minutes recording these reviews convert routine oversight into legal protection.

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