Question 1

How can I prove to my client that their Rx Rebates are being 100% passed back?

Accepted Answer

Brokers must verify actual dollar-for-dollar transparency. 4C Digital Health monitors contracted vs. actual discounts and ensures 100% of pharmacy rebates are passed back to the plan, providing objective data to hold PBMs and TPAs accountable.

Question 2

Can I forecast the financial impact of a plan design change before implementation?

Accepted Answer

Using Benefit Design Modeling, brokers forecast the impact of changes using historical data. This establishes a diagnostic baseline to move from reactive renewals to strategic optimization and measurable ROI.

Question 3

How do I identify if my plan is paying for 'Impossible Day' billing?

Accepted Answer

Standard TPA filters often miss anomalies like 'Impossible Day' claims. 4C Digital Health audits 100% of claims for clinical integrity to stop leakage at the source and prevent automated billing errors.

Question 4

Does our PBM contract comply with the CAA 2026 100% rebate pass-through mandate?

Accepted Answer

The CAA 2026 requires 100% of manufacturer rebates be remitted within 90 days. We verify every dollar of remuneration is accounted for, ensuring PBMs aren't retaining rebates through affiliated aggregators.

Question 5

How do we identify 'spread pricing' under the 2026 DOL PBM Disclosure Rules?

Accepted Answer

DOL now requires disclosure of drug-level spread compensation. 4C Digital Health cross-references PBM 'buy prices' against plan 'sell prices' in real-time to identify non-transparent pricing methodologies.

Question 6

What constitutes a 'prudent process' for benchmarking TPA administrative fees in 2026?

Accepted Answer

Under DOL safe harbor frameworks, fiduciaries must use a structured, well-documented benchmarking process. 4C Digital Health automates this with continuous TPA performance diagnostics.

Question 7

What is the fiduciary risk of 'Gag Clauses' in 2026 service provider contracts?

Accepted Answer

Fiduciaries are prohibited from contracts limiting access to claims data. 4C Digital Health serves as the tool for exercising your 'right to know,' proving no gag clauses hinder required real-time monitoring.

Question 8

Does our Fiduciary Liability Insurance cover failures in TPA oversight?

Accepted Answer

Most policies require proof of a 'prudent process' for coverage. 4C Digital Health provides the digital paper trail and active management evidence required by insurers to prove reasonable steps to prevent FWA.

Question 9

How do real-time plan changes impact our 2026 Form 5500 filings?

Accepted Answer

Accurate Form 5500 reporting requires precise data on administrative expenses. 4C Digital Health provides the diagnostic baseline for accurate filings by aggregating all fees throughout the plan year.

Question 10

Can we audit our TPA’s 'Indirect Compensation' without a formal autopsy?

Accepted Answer

The CAA 2026 requires disclosure of all indirect compensation. 4C Digital Health provides data transparency to flag undisclosed commissions in real-time, aiding compliance with federal mandates.

Question 11

How do I monitor 'Operational Integrity' to ensure TPA speed isn't causing balance billing?

Accepted Answer

4C Digital Health tracks 'Time to Pay' and TPA denial rates. This allows fiduciaries to proactively address TPA inefficiencies before they result in member appeals or provider frustration.

Question 12

How can I tell if employees are being steered toward high-cost providers?

Accepted Answer

Plan spend is often driven by referral patterns toward high-cost facilities. 4C Digital Health analyzes provider practice styles to identify low-value care and steer members toward high-value providers.

Question 13

Is my stop-loss deductible being protected by active subrogation tracking?

Accepted Answer

4C Digital Health provides continuous monitoring of subrogation and COB to ensure the plan is the payer of last resort, ensuring recoveries are realized in real-time rather than lost to oversight.

Question 14

How can a plan sponsor verify if their TPA is meeting ERISA fiduciary standards?

Accepted Answer

Verification requires independent data validation beyond TPA summary reports. 4C Digital Health audits claims against plan documents in real-time to support ERISA oversight duties.

Question 15

How do we document 'Reasonable Expenses' for PBM specialty drug programs?

Accepted Answer

4C Digital Health provides drug-level net pricing to determine if specialty programs are cost-effective, ensuring fiduciaries manage plan assets based on data-justified clinical pricing.

Question 16

How does the 2026 'Affiliated Pharmacy' disclosure affect our fiduciary risk?

Accepted Answer

PBMs must now disclose if benefit designs favor affiliated pharmacies. 4C Digital Health analyzes data to identify methodologies that obscure actual costs and steerage that may lead to higher margins.

Fiduciary FAQs