Health Plan Fee & Compensation Review
Your plan's TPA, PBM, and broker now have to disclose what they are paid. We collect those disclosures, normalize what every vendor receives, and hand you the documented record.
This is a new VVIDAI service line, still in development. We are taking a small number of early engagements and preparing each review by hand while the platform is being built.
What changed in February 2026
The Consolidated Appropriations Act, 2026 was signed on February 3, 2026. It expanded ERISA Section 408(b)(2) so that PBMs and third-party administrators — not just brokers and consultants — must disclose their compensation to the plan fiduciary.
Receiving the disclosure is not the end of it. The plan fiduciary has to determine whether the compensation is reasonable, and be able to show how that determination was made.
That obligation returns every time a contract is entered into or renewed.
Timing
- Disclosure obligation
- Already in effect
- PBM periodic reporting
- Plan years beginning after August 3, 2028
- Rebate pass-through
- Within 90 days of quarter end
The expanded definition of covered service provider was enacted without an explicit effective date. Absent further guidance, it is generally read to apply to contracts entered into or renewed on or after February 3, 2026. Confirm timing with your counsel.
What you get
Delivered as a PDF, with the minutes in editable form.
- A vendor inventory: broker, TPA, PBM, stop-loss, point solutions
- Every compensation amount we found, with the source document cited
- All of it normalized to one basis, per employee per month
- Direct and indirect compensation separated
- What was not disclosed, and a request letter ready to send
- A reasonableness finding, vendor by vendor
- Meeting minutes ready for your file
- The original disclosures, attached
Four vendors. Four bases. One column.
A disclosure arrives as an annual fee, a per-employee rate, a per-member rate and a percentage. None of them compare until they are converted.
| Vendor | As disclosed | Per employee per month |
|---|---|---|
| Broker | $48,000 per year | Per employee per month$4.00 |
| TPA | $23.50 per employee per month | Per employee per month$23.50 |
| Stop-loss | $13.20 per member per year | Per employee per month$1.10 |
| PBM | 3.1% of drug spend | Per employee per monthNot disclosed |
| Documented | $28.60 | |
One vendor is still unaccounted for. That gap is the finding.
How it works
- 01
You send the documents
The disclosures you received, vendor contracts, a recent plan invoice, covered lives, and your renewal date. No claims data. Nothing clinical.
We never ask for protected health information.
- 02
We build the record
We extract every amount, convert them to a common basis, and flag what is missing.
- 03
You get the file
A report you can put in front of your committee, your client, or your counsel.
Who this is for
A good fit
- Employers with 100 to 2,500 covered lives
- Self-funded and level-funded plans
- Independent advisors and TPAs who need this for a book of clients
- ERISA counsel and fractional CFOs
Not a fit
- Plans under 100 participants
- Anyone looking for a legal opinion
- Anyone looking for a broker or carrier recommendation
Pricing
Every engagement is quoted individually. What it takes depends on how many vendors are involved, how much they actually disclosed, and how much has to be chased down — so we look at your plan first, then give you a figure.
Annual reviews and ongoing work are quoted the same way.
Advisors with a book of clients: license pricing on request.
We do not price as a percentage of savings found.
Ask for a quoteWho does the work
I read the disclosures myself. I trace every amount back to the document it came from, convert it to a common basis, and write the finding — so you can see how each number was reached and defend it later.
VVIDAI, Inc. is the company behind this work, with the same engineering discipline behind Leviqa, our product for explainable customs classification.
VVIDAI, Inc.Dover, Delaware, USA
What this is not
This is an analysis and documentation service. It is not legal advice, not a compliance opinion, and not a recommendation of any plan, broker, or carrier. The determination and the signature remain yours.
Request a sample report
Tell us about the plan and we will send a sample report, plus an honest read on whether this review is worth your time.
Health Plan Fee & Compensation Review is a service of VVIDAI, Inc.. It is an analysis and documentation service — not legal advice, not a compliance opinion, and not a recommendation of any plan, broker, or carrier.
Contact contact@vvidai.io