Given that there are only 500,000 401k plans but over 6,000,000 health plans (almost all of which have related cafeteria plans) I think it's very smart to start gearing up for welfare benefit plan compliance services as the "next big thing". I gave a presentation on this topic at ASPPA and will be giving another at NIPA BMC next month in case you're interested in the handouts.
The access to the employer checking account is surprisingly rare given the ease of providing for compliance. Most arrangments simply violate the rules by having an account maintained by the provider. I don't know if the DOL non-enforcement policy extends to the ERISA bond (it probably would because the non-enforcement is based on the idea the the funds are employer assets in an employer account), but ERISA bonds are extremely inexpensive.