"[An] employer must ensure that the fees charged for partnering with the private exchange are reasonable. If commissions are paid (in the case of a fully-insured private exchange), the employer should weigh whether these commissions are reasonable, and the employer should ensure that 'steering' is not occurring ... If an employer decides to partner with a single-carrier private exchange, the employer should ensure that the premium rates for plans inside the private exchange are competitive with plans sold outside of the exchange. Finally, regardless of whether the employer will offer fully-insured or self-insured plans, an employer must weigh whether a conflict of interest is present in cases where a benefit consulting firm is seeking to offer its private exchange capabilities to the employer's employees."

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