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I was under the impression that bundled providers were to provide separate, to some extent, fees that are related to basic TPA roles such as compliance testing and Form 5500. I am reading one such disclosure. For services it refers reader to an unattached, previously provided, document called 'Recordkeeping and Administrative Services Agreement'. It then says 'Consistent with this “packaged” structure, the compensation and fees we receive are not broken out into a fee for each specific service we provide.' I may be naive but it would seem that such providers would have different cost structures whether the plan is bundled or not which would make this easy to disclose. I also thought this was required by 408(b)(2). Is this disclosure really sufficient?

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