Methodology
·A defensible Investment Policy Statement — for your health plan
We borrow the discipline from the 401(k) side and translate it line-by-line to the welfare-plan context. Template included.
Every well-governed 401(k) plan operates under a written Investment Policy Statement. The IPS specifies how investments are chosen, monitored, and replaced. It is the first document a Department of Labor auditor asks to see. It exists because the retirement-plan side of ERISA has had thirty years to develop case law around what 'prudent' means in practice.
The welfare-plan side is younger, and the analog document is rarer. That is starting to change.
The welfare-plan IPS, in nine sections.
Plan purpose and benefit philosophy. Stakeholder governance. Compensation framework and 408(b)(2) attestation. Network and PBM evaluation criteria. Stop-loss procurement standards (no-laser default, attachment-point methodology, market RFP cadence). Pharmacy spend monitoring (rebate pass-through, spread pricing prohibition). Compliance posture (CAA, MHPAEA, HIPAA). Reporting cadence. Review and amendment process.
Each section runs about a page. The full template is published to clients under engagement; the structure is described above precisely because there should be no proprietary moat around governance discipline.
ERISA counsel of record, reviewed 2026-03-20
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