TrueNorthFiduciary Risk Advisors
Service · Plan Design

Plan design as a fiduciary act — defensible, documented, and reviewed by ERISA counsel.

We design plan documents that reduce trend without shifting cost to families. Reference-based pricing where defensible, direct provider contracts where the math works, and a documented decision record that a CFO can defend to a committee.

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Scope

Design the plan around the population, not the carrier's catalog.

Plan design starts with claim distribution analysis, not the carrier's spring product brochure. We pick the components and write the document; we do not double as the TPA.

In scope

  • Claims distribution analysis (12–36 months) by diagnosis, site of care, and provider
  • Network strategy: BUCA, RBP, direct contract, or hybrid
  • Cost-sharing structure modeled against employee out-of-pocket distribution
  • Plan document drafting, in coordination with ERISA counsel
  • Employee communication design — pre-OE, OE, and steady-state
  • Annual plan-design refresh and committee minutes

Out of scope

  • Carrier or TPA selection (separate procurement engagement)
  • Wellness program design (third-party vendor)
  • Final legal review of plan document (ERISA counsel of record)
Methodology

How we operate — step by step, in writing.

  1. 01

    Claims distribution analysis

    We rebuild the claim distribution by diagnosis code, site of care, and provider — not just the carrier's top-line cost-trend summary. Plan design follows the distribution. A 70/30 PPO is the wrong answer in a population where 4% of members drive 65% of spend.

  2. 02

    Network strategy

    BUCA networks bundle 20–35% margin into the discount. Reference-based pricing or direct provider contracts strip that margin while preserving member access where the contracted provider is local. We model member disruption against savings and recommend a defensible posture.

  3. 03

    Cost-sharing without cost-shifting

    Increasing the deductible is the carrier-default lever. We model cost-sharing against the employee out-of-pocket distribution, not the average — because the average masks the employees for whom a $3,000 deductible is structurally unaffordable.

  4. 04

    Documented committee record

    Plan-design decisions are documented in the committee minutes with the rationale, the alternatives considered, and the projected impact. Under ERISA §404(a)(1)(B), the documented prudent process is the defense — not the outcome.

Deliverable schedule

What lands on the committee table, and when.

DeliverableCadenceDetail
  • Plan-Design DiagnosticOn engagementClaims distribution analysis, network leakage map, OOP exposure distribution.
  • Plan-Design Recommendation MemoAnnuallyNetwork, cost-share, formulary, and stop-loss alignment. Signed by the engagement principal.
  • Committee Minutes TemplateAnnuallyPre-formatted minutes capturing alternatives considered and decision rationale.
  • Annual OE Communication KitAnnuallyPre-OE, OE-window, and post-OE messaging. Plain-language SBC walk-through.
Fee structure
Flat annual retainer$22,000 – $78,000 per plan-year

Range scales with covered lives (50–5,000) and number of plan options. Quoted in writing in Schedule A.

The corresponding 408(b)(2) compensation disclosure is published at /legal/408b2 and refreshed quarterly.

Related engagements

Most engagements bundle these services into a single Schedule A.

The next step is a fiduciary audit, scoped to plan design.

Two minutes to scope the engagement. One business day to a calendared 30-minute call with a principal. No carrier in the room. Engagement letter follows in writing.

Request a Fiduciary AuditRead our 408(b)(2) disclosure