TIER 2 · ERISA FIDUCIARY · COMPLIANCE AUDIT
ERISA's Five Words Define Your Personal Exposure.
The Documentation Is What Survives the Audit.
A 2-page printable worksheet PBS uses across 100s of PBM contract reviews annually. Free download. Sent to your inbox.
Three audit passes against the ERISA prudence standard
How the five-word duty maps to pharmacy-benefit decisions
The decision log that documents prudent process
The co-fiduciary defense for the committee
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A complete audit framework you can run in half a day.
WHAT IS IN THE WORKSHEET
PASS 03
Document the Co-Fiduciary Defense
Prudence is proven by process, not outcome. The audit builds the decision log that shows how each material pharmacy-benefit choice was made, on what information, and with what advice.
PASS 01
Apply the ERISA Standard
ERISA's duty turns on a few words: acting prudently, solely in the interest of participants. The audit maps that standard onto the pharmacy-benefit decisions your committee actually makes.
PASS 02
Build the Decision Log
Prudence is proven by process, not outcome. The audit builds the decision log that shows how each material pharmacy-benefit choice was made, on what information, and with what advice.
ACTION PLAN
This Quarter's Action Plan
Run the three passes, build the decision log, and close the documentation gaps. The pharmacy benefit is a fiduciary act whether the committee treats it as one or not.