FAQs

Frequently Asked Questions About Independent RFP Evaluations

Straight answers to the questions plan sponsors, committees, and counsel ask most — about the RFP process, fiduciary obligations, timelines, and how Culpepper RFP works. If your question isn't here, schedule a call and ask it directly.

Does ERISA require us to conduct an RFP?

ERISA does not explicitly require an RFP, but it does require fiduciaries to follow a prudent, documented process when selecting and monitoring service providers — and to ensure the fees paid are reasonable for the services received. When that process is reviewed by the Department of Labor or challenged in litigation, a structured, independent RFP is the clearest evidence that the duty was met. The requirement is the process; the RFP is how most plan sponsors demonstrate it.

The four members on the team have more than 60 years of practical experience buying, selling, evaluating, and sourcing cybersecurity consultants/vendors plus our ERISA experience.

Should we outsource the RFP process or run it internally?

If your team lacks the time, current market data, or documentation practices to run a structured evaluation, outsourcing to an independent third party is usually the more defensible path. Internal evaluations tend to struggle in three predictable places: incomplete market comparisons, internal relationships influencing the outcome, and thin documentation — which are exactly the gaps regulators and plaintiffs' attorneys look for. An outside evaluator closes all three while consuming far less executive time.

Can our broker or advisor run their own RFP?

A provider evaluating its own competitors has an inherent conflict of interest, even with the best intentions. The evaluation may be thorough, but it is difficult to defend as objective if the process is ever reviewed — and 'who ran the evaluation' is one of the first questions asked. An independent evaluator with no financial ties to any bidder removes that question entirely.

What does the Culpepper RFP process include?

Every engagement follows a documented sequence: scoping and evaluation criteria established with your committee before any proposal is reviewed, structured RFP development and distribution, consistent scoring applied to every respondent, finalist presentations and comparison support, and a complete decision file — criteria, comparisons, scoring, and rationale — that your organization retains. The deliverable is not just a recommendation; it is the documentation that supports it.

How long does an evaluation take?

It depends on the level of engagement. Fee and service benchmarking typically takes about 45 days. An RFI takes roughly 60 days. Most full RFP evaluations are started and completed within 100 days, with shorter and longer exceptions depending on the provider category and complexity. We confirm the timeline during scoping, before the engagement begins.

How much of our team's time will this take?

Far less than running it yourselves. Culpepper RFP handles the drafting, distribution, respondent management, scoring, and documentation. Your team's involvement is concentrated at two points: setting evaluation criteria at the start, and participating in finalist reviews at the end. For most committees, that amounts to a handful of meetings rather than months of staff work.

What makes an RFP process defensible?

A defensible RFP has four elements: evaluation criteria established before proposals are reviewed, a consistent comparison applied to every bidder, documentation of how each decision was reached, and independence from the providers being evaluated. Outcomes can be debated; a sound, documented process is what withstands review.

What happens after the evaluation is complete?

You receive the complete decision file — evaluation criteria, vendor comparisons, scoring, and the rationale for the recommendation — along with support presenting the results to your committee or board. Selection is not the end of fiduciary oversight: we also recommend a monitoring and benchmarking cadence so the decision you just documented stays defensible over time.

How often should we evaluate our recordkeeper or advisor?

Most plan sponsors benchmark fees and services every one to two years and conduct a full market evaluation every three to five years, or sooner when circumstances change. Regular, documented review is itself evidence of ongoing fiduciary oversight — the duty to monitor does not end when a provider is selected.

What triggers a fiduciary review of our providers?

The most common triggers: a plan merger or acquisition, your provider being acquired or consolidating, a material fee change, service problems, litigation activity in your industry, a recommendation from ERISA counsel, or simply a long gap since the last documented evaluation. If you cannot point to a documented review in the last several years, that gap is itself the trigger.

Is benchmarking enough, or do we need a full RFP?

Benchmarking answers whether your current fees and services are reasonable relative to the market; an RFP answers whether a better arrangement is available. Benchmarking is often the right first step — and if the results are competitive, it may be all you need. We discuss with clients which level their situation calls for before any engagement begins.

Do fiduciary rules apply to our health plan and benefits broker?

Yes — and the obligations are expanding. The Consolidated Appropriations Act (CAA) extended fee-disclosure requirements to group health plans, which means plan sponsors are now responsible for understanding what their brokers and consultants are paid, from every source, and confirming that compensation is reasonable. The scrutiny that reshaped retirement plans — fee transparency, documented provider selection, litigation over process — is now arriving in health benefits.

What broker compensation should we be asking about?

All of it — direct and indirect. Beyond stated commissions, brokers and consultants may receive administrative override fees, per-employee-per-month (PEPM) payments, stop-loss participation fees, back-end rebates, and bonuses tied to carrier or vendor placement. Under the CAA, covered service providers must disclose this compensation, and plan sponsors have a duty to review it and assess whether it is reasonable. If you have never seen an itemized accounting of everything your broker is paid, requesting one is the place to start.

What is an MHPAEA comparative analysis — and do we need one?

The Mental Health Parity and Addiction Equity Act requires plans that impose non-quantitative treatment limitations on mental health or substance use benefits to maintain a written comparative analysis demonstrating parity with medical and surgical benefits — and the Department of Labor can request it. Many plan sponsors discover they do not have one until the request arrives. Culpepper RFP helps sponsors run a structured selection process for firms qualified to perform the analysis.

How is Culpepper RFP compensated?

Culpepper RFP is paid directly by the client, with the fee disclosed in full before the engagement begins. We accept no compensation from providers, brokers, coalitions, or vendors — no referral fees, no revenue sharing, no placement arrangements — and our fee does not change based on which provider is selected. Fees vary with the scope of the engagement, and we quote them after an initial conversation about what your situation requires.

What experience does the Culpepper RFP team have?

The team has sat on all sides of the fiduciary table: an international investment consulting firm, two of the largest recordkeepers, and what was at the time the largest investment management firm in the US — plus direct experience as plan fiduciaries, investment committee members, and evaluators of health benefit brokers and consultants. That insider's perspective is the point: we know how providers price, how they present, and where proposals and reality tend to diverge, because we have been on the other side of the table.

What size organizations do you work with?

Our three engagement levels — benchmarking, RFI, and full RFP — exist so the scope and fee can fit the situation rather than forcing every client into the same process. We have completed dozens of evaluations for retirement, benefit, and endowment & foundation service providers across organizations of all sizes.

Can we speak with references?

Yes — every one of them. 100% of Culpepper RFP clients can act as a reference. We will connect you with organizations similar to yours in size, plan type, and situation before you make any commitment.

Do you help with DOL cybersecurity audit requirements?

Yes. The Department of Labor expects plan fiduciaries to assess the cybersecurity practices of their service providers, and many sponsors engage an outside firm to perform that audit. Culpepper RFP runs the selection process for cybersecurity audit firms the same way we run every evaluation: independent criteria, structured comparison, and full documentation. The team combines decades of experience buying, selling, and evaluating cybersecurity consultants with our ERISA background.