"These novel lawsuits challenging voluntary benefits are not only notable for what they allege, but also because they implicate consultants and brokers.... [P]laintiffs may be leveraging data gathered regarding service provider compensation disclosed pursuant to the [CAA] ... [E]mployers should consider creating a process to monitor voluntary benefit programs offered to their employees, including the commissions charged by the various brokers, akin to what many employers maintain to monitor retirement plans and health plans."  MORE >>