Sarah Borders January 29, 2026 2 min read

Under the Radar - Fiduciary Lawsuits

Purpose:

  • In 2025, there were several major fiduciary lawsuits against large employers over alleged breaches of fiduciary management of health plans, and this new wave focuses on voluntary benefits.
  • Plan participants and plaintiff attorneys appear poised to challenge how expensive benefit plans are becoming and are looking for ways with new transparency measures to hold fiduciaries accountable to act solely in the best interest of participants.

Additional Information:

Schlichter Bogard LLC is a well-known law firm that, for the last 15-20 years, has successfully challenged employers for exorbitant fees and poor performance in retirement plans. Court decisions and settlements on those cases led to industry-wide shifts in fiduciary accountability for retirement plans. In the final week of 2025, the firm launched four new lawsuits against large employers and their large insurance brokers alleging that fiduciaries of voluntary plans have improperly charged employees substantially more than the claims justify, with only 25% to 35% funding claims, and up to 40% of what employees pay used to pay commissions to brokers.

Practical Impact to Employers:

The employer, and specifically the decisionmakers and others with authority over the benefit plans, are fiduciaries of those plans and must manage them prudently, acting solely in the best interest of participants. Third parties, including insurance brokers, may also be functional co-fiduciaries or willing participants in known breaches of fiduciary duties. So, it is vital employers efficiently document the process each year that goes into selecting service providers, benefit offerings, fees, and more. It is not always about going with the lowest cost option, but rather about choosing what is best for participants overall. So, having a fiduciary committee with various employee representatives providing input is instrumental.

avatar

Sarah Borders

Principal, Benefits Compliance Solutions. Sarah has spent the last 15 years in the employee benefits industry, has numerous designations and serves on NAHU’s Employer Working Group Subcommittee and is an active board member of Austin AHU. She recently stepped down as Vice President of Benefits Compliance at one of the nation's largest brokerage firms to start her own compliance consulting practice. Her designations include an active license with the Texas Department of Insurance, CEBS (Certified Employee Benefits Specialist), Certified Health Care Reform Professional, HIPAA certification and Health Care Service Associate. She holds an MBA from Texas A&M Corpus Christi and a BA from University of Incarnate Word. Her consulting firm, Benefits Compliance Solutions, partners with employers to identify unknown risks and avoid hundreds of thousands of dollars in fines and lawsuits from failure to comply with their healthplan obligations.

COMMENTS