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Fiduciary Responsibility in Healthcare Plans
Fiduciary Plan Governance, LLC 
[Opinion] May 3, 2018
"An employer's management of the payment part is what raises fiduciary issues under ERISA. We know plan sponsors have fiduciary responsibilities for ERISA retirement plans like 401(k)s and 403(b)s but what's not as well understood is that, speaking very broadly, employers offering healthcare plans are obligated to act reasonably and prudently, to engage only necessary services, and not enter into unreasonable arrangements or pay unreasonable fees."
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