Though ERISA is often thought of as an issue for retirement plans, the law has always applied to employer-sponsored health benefit plans. The Consolidated Appropriations Act of 2021 (CAA) sought to put a spotlight on the issue by clarifying responsibilities of health benefit plan fiduciaries and the third-party service providers they contract with. Yet, 3 years after its passage, many plan sponsors still can’t get their vendors or advisors to provide the required fee disclosures.

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