Independent Benefits Broker RFP Evaluations
If you're being asked to document broker fees and services — or to confirm that what you're paying is reasonable — a structured, independent RFP brings clarity without your team having to manage every detail.
When Do Plan Sponsors Evaluate Their Broker?
This is usually a fit when renewals feel heavier than they should, service has become inconsistent, leadership is asking for a market check, or you simply need cleaner documentation of broker fees and value for your files.
Increasingly, there's a fifth trigger: your ERISA counsel has asked whether you can demonstrate that your broker's total compensation — from every source — is reasonable. For most plan sponsors, the honest answer is that they've never seen the full number.
What the Consolidated Appropriations Act Means for Plan Sponsors
The Consolidated Appropriations Act (CAA) of 2021 extended to group health plans the kind of fee transparency that reshaped retirement plans over the past two decades. Brokers and consultants must now disclose their compensation — direct and indirect — and plan sponsors have a fiduciary duty to review that disclosure and assess whether the compensation is reasonable for the services provided.
That responsibility cannot be delegated to the broker. And broker compensation is rarely just a stated commission — it can include administrative override fees, per-employee-per-month (PEPM) payments, stop-loss participation fees, back-end rebates, and placement bonuses. If you have never seen an itemized accounting of all of it, you are not yet in a position to assess reasonableness.
The pattern is familiar. Fee transparency, documented provider selection, and litigation over process transformed how retirement plans are managed. The same forces are now arriving in health benefits — and the plan sponsors who document their broker decisions early will be the ones with nothing to scramble for later.
We Suggest That Every Broker We Evaluate Must Commit
— In Writing
Culpepper RFP suggests every broker included in an evaluation to provide a written fiduciary commitment as a condition of participation. Not language that sounds fiduciary — 'we always act in our clients' best interests' — but a written, legal commitment to fiduciary status.
The distinction matters. Fiduciary-sounding language is marketing; a written fiduciary commitment is enforceable. Brokers willing to make that commitment tend to have compensation structures they're comfortable putting in front of you. Brokers who decline are telling you something worth knowing before you sign — not after.
How the Broker RFP Process Works
Identifying brokers that fit your size, location, and required services
Writing the RFP and managing the evaluation from start to finish
Organizing evaluation criteria so every comparison is consistent
Requiring written fiduciary commitments from every participating broker
Handling all broker communication during the evaluation period
Collecting and reviewing full compensation disclosures under the CAA
Summarizing results and presenting findings to your committee
Coordinating finalist presentations and agendas
Managing reference checks
Supporting final fee negotiation based on the broker's disclosed compensation
Our References Are Our Clients — All of Them
Our clients engage us for independent evaluations at sensitive moments — often at the direction of counsel — so we don't publish named testimonials or case studies. Discretion is part of the engagement.
What we offer instead is stronger: 100% of Culpepper RFP clients can act as a reference, a standard we've maintained since the firm began. When you're seriously evaluating whether to work with us, we'll connect you directly with organizations similar to yours in size, plan type, and situation — and you can ask them anything.
Looking for a different evaluation? We also run independent evaluations for retirement plan providers, OCIO managers, actuarial, and DOL Cybersecurity Firms— each covered on its own page.
Questions Plan Sponsors Ask About Broker Evaluations
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It's for you — more than ever. Under the CAA, responsibility for reviewing broker compensation sits with the plan sponsor, which in practice means HR and Finance. ERISA attorneys often make the referral, but the people who engage us and run point are HR Directors, CFOs, and benefits committees. You don't need to be a benefits expert; that's what you're hiring.
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A long relationship is not a fiduciary problem — an undocumented one is. If your broker is delivering competitive value, a structured evaluation will show it, and the relationship comes out validated and documented instead of assumed. If the evaluation surfaces gaps, you needed to know regardless of the relationship. Either way, 'we've been with them for years' is not an answer that holds up when someone asks how you determined the fees were reasonable.
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A broker running a market comparison of its own competitors — and its own compensation — has an unavoidable conflict of interest, however capable and well-intentioned they are. The result may even be accurate, but it is not independent, and it is difficult to defend if the process is ever reviewed. The evaluation of a provider should not be run by the provider being evaluated.
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We handle broker research, RFP writing, distribution, all broker communication, compensation disclosure collection and review, scoring, summaries, finalist scheduling, reference checks, and negotiation support. Your involvement concentrates at two points: setting evaluation criteria at the start, and finalist presentations at the end, where the decision is yours.
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Broker relationships are often long and personal, which is exactly why an independent process helps. When a third party runs the evaluation, the criteria — not anyone on your team — drive the outcome. Your incumbent competes on the same footing as everyone else, nobody internal has to play the critic, and if your incumbent wins, the relationship is stronger for having been documented rather than assumed.
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No — decoding broker compensation is a core part of the engagement. Commissions, overrides, PEPM fees, stop-loss participation fees, back-end rebates: we itemize what each broker would earn, from every source, and put it in front of your committee in plain terms. Most sponsors see the full picture of their broker's compensation for the first time during this process.
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For most committees, a handful of meetings across the engagement — criteria-setting at the start, a findings review in the middle, and finalist presentations at the end. The process is designed to consume our hours, not yours.
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You don't have to know — that's the first thing we figure out together. Benchmarking answers whether your current broker's fees and services are reasonable; an RFI gathers structured market information; a full RFP is a complete documented search. We consult with you on which level your situation calls for before any engagement begins.
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Yes — every client we've ever worked with. 100% of Culpepper RFP clients can act as a reference. Once you're seriously evaluating an engagement, we'll connect you with organizations similar to yours, and what you ask them is up to you.
Could You Document How Your Broker's Fees Were Determined to Be Reasonable?
If the answer is no — or 'not confidently' — schedule a call with Jay. You'll leave knowing whether an evaluation makes sense, what level fits, and what the process would look like.