"Many employer and other plan sponsors and fiduciaries ... are surprised to discover their plans and they are exposed to or actually have already paid significantly higher than projected out-of-network costs due to the use of cost data indefensible under these rules, failures by their vendors to timely handle or other bungling of IDR rules responsibilities or both.... Keeping in mind that the [DOL] views NSA administration and selection, oversight and management, and compensation of vendors as fiduciary conduct, employers also should verify that vendors handling these duties assume named fiduciary status for these responsibilities[.]"  MORE >>