Jamie Greenleaf

With raised fiduciary expectations, the health benefits market will move toward more transparent, level-fee structures and fiduciary-aligned advice.

Transparency is becoming the baseline, with visibility into compensation streams and financial relationships increasingly expected rather than optional.

The opportunity ahead is about building the same kind of thoughtful, documented, process-driven governance in health care that transformed retirement plans.

Just as hidden fees became the hallmark issue in 401(k) fiduciary litigation, shared savings is quickly becoming the next flashpoint in health plan oversight.

Nothing in the court's ruling reduces or eliminates the fiduciary obligations that health plan sponsors must uphold under ERISA.

Ignoring new requirements will cost fiduciaries and vendors time and money.

Employers will need to acknowledge they are a plan fiduciary, establish a committee to manage the process and document all administrative decisions.

As employers establish procedures to manage their liabilities under the Consolidated Appropriations Act, brokers will be held to a new standard.