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New Mandatory Disclosure Requirements Enacted for ERISA Health Plan Fiduciaries Under CAA 2026
Boutwell Fay LLP
[Guidance Overview] Feb. 24, 2026 "plan fiduciaries will need to promptly ... [1] Create an inventory of existing service providers and vendors to their ERISA covered health plans ... [2] Determine if appropriate fee disclosures have been obtained from such vendors/service providers; [3] If [not], request them from the vendors/service providers; [4] Once obtained, review the fee disclosures and service relationships ... [5] If a vendor/service provider does not respond to requests for fee required disclosures, consider next steps, which could involve terminating the relationship and reporting the vendor to the DOL. [6] Keep a record of fulfilling these fiduciary functions." MORE >> |
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