Consulting Expenses of Plan Sponsor

[Guest budman]

A plan sponsor of a self-funded group welfare plan wants to reimburse themselves for consulting fees on their plan. We are the TPA and feel this may be a prohibited transaction and are also concerned about our role in this request as a fiduciary. We bill the client by location and cut the checks for administrative expenses, stop loss, etc. They are requesting that we add an amount per member per month to the bill for their consulting on the plan and then once each location has paid, cut a check back to the company for that amount. They do contribute a good deal of time in the administrative aspect of the plan so therefore feel this is a justified expense to the plan. Has anyone ever run across this situation because we have never heard of this being done?