The Fiduciary File

Prove the process. Every year, in one place.

ERISA judges how you decided, not what you decided. This is the file that shows it: every obligation for your plan, dated and owned, with the evidence next to it — plus the committee, vendor, and cost reviews that turn "we looked" into something you can hand to counsel.

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Set up your plan to start

Twelve questions. The register, calendar, and vendor pages build themselves from the answers.

About the plan

As it appears on the plan document / 5500.
Drives 20+ (COBRA / Medicare secondary), 50+ (ACA employer mandate), 100+ (Form 5500).
Enrolled employees. Form 5500 is required at 100+.
Only fill this in if pharmacy is carved out to its own PBM contract. If Rx is bundled — fully insured, level-funded, or an ASO/TPA package that includes the PBM — leave it blank and it renews with the plan. Either way, the CAA 2026 disclosure obligation attaches at that renewal.
Everything stays on this device. Export to keep a copy.

Already have a file?

Drop your exported .json here — or tap to choose it. Everything reloads exactly where you left it: statuses, owners, evidence, committee, vendors. Update, then export again. The exported file is the record; this page is the editor.

Where your data lives

This is a static page. There is no server behind it, no database, no account. What you type is stored in this browser, on this device, and goes nowhere until you click Export — which writes a file to your own computer. The page makes no network requests after it loads (open your browser's Network tab and type in a field: nothing fires). Session-recording analytics used elsewhere on this site are not installed on this page or on client renewal pages. The URL is set to noindex, no-store. If you clear your browser data, the file on this device is gone — export after every meeting and keep the file with the evidence it points to.
What this is and isn'tA system of record for the fiduciary process — what was reviewed, when, by whom, and where the evidence lives. It documents that a review occurred; it does not certify compliance with ERISA or any other law. Deadlines shown are the general federal rules for calendar-year and non-calendar-year plans; confirm specifics with counsel, and expect this page to be updated as CAA 2026 and the DOL's PBM disclosure rule are finalized.

Every obligation that applies to this plan, grouped the way a fiduciary thinks. Set a status, an owner, a date, and where the evidence is. "N/A" removes an item from the score with a reason — which is itself evidence.

Every dated item on your plan year, in order. Red is overdue. Gold is inside 45 days.

The committee is the process. A charter says who decides; minutes say what they decided and why; the training log says they knew what they were doing. Defense counsel asks for these three things first.

Members

Meeting log

Cadence that holds upQuarterly. Q1: prior-year claims and the 5500/PCORI/RxDR prep. Q2: vendor fee review and 408(b)(2)/PBM disclosures. Q3: renewal review (the Renewal Story + Fiduciary Record). Q4: gag-clause attestation, notices, and next-year decisions.

Fiduciary training log

Charter — starting template


    
Minutes — starting template

  


  
  

    
One row per party that touches plan money or plan data. For each: what they're paid, when it was last disclosed and reviewed, when it was last benchmarked and bid. This is where CAA 2026 lives.

    
VendorServiceHow paidAnnual comp408(b)(2) disclosure receivedReviewed by committeeLast benchmarkedLast bid / RFPContract endsAudit rights

      

    

    
CAA 2026 and the DOL proposed rule, in one paragraphPBMs are now covered service providers under ERISA 408(b)(2): they must disclose all direct and indirect compensation, and it must be reasonable, or the contract is a prohibited transaction. The DOL's proposed rule (comment period closed March 2026) would add initial and semiannual disclosures for self-insured plans and an annual audit right the PBM can't limit — with a fiduciary safe harbor only for sponsors who review and act on what's disclosed. The 100% rebate pass-through and semiannual pricing reports phase in for plan years starting 2028–2029. Practical translation: get the disclosure at renewal, minute the review, keep both.

  


  
  

    
The binder index. Print it, sign it, file it with the evidence it points to. Export the JSON so the file survives a laptop.

    
Index

    
Annual cost-oversight minute
Each renewal, the Fiduciary Record generated by your Renewal Story is the minute for the cost-oversight review — what was reviewed, every alternative considered with expected and maximum cost, the criteria, the decision, the rationale. It files here under Cost oversight. One a year; in three years you have a history nobody can argue with.

    
Evidence conventions
Use the same folder structure every year: /Fiduciary File/<plan year>/01 Governance · 02 Plan documents · 03 Filings & attestations · 04 Notices · 05 Vendors · 06 Claims & appeals · 07 Cost oversight. The "Evidence" field on each item is the path or the document name. A regulator or plaintiff asks for a specific document with a specific date; this is how you find it in a minute.