Jamie Greenleaf

Nothing in the court's ruling reduces or eliminates the fiduciary obligations that health plan sponsors must uphold under ERISA.

Ignoring new requirements will cost fiduciaries and vendors time and money.

Employers will need to acknowledge they are a plan fiduciary, establish a committee to manage the process and document all administrative decisions.

As employers establish procedures to manage their liabilities under the Consolidated Appropriations Act, brokers will be held to a new standard.