# Benefits Dirty Dozen, Part 2. Health plan tactics 6 to 1. Source: https://ethosbenefits.com/podcast/benefits-dirty-dozen-part-2 Type: Podcast episode Series: The Business of Benefits, Episode 89 Published: 2026-10-22 Duration: PT57M1S Hosts: Chelsea Ryckis, Founder and President, Ethos Benefits; Donovan Ryckis, Founder and CEO, Ethos Benefits; Patrick Ansara, Partner and Director of Client Operations, Ethos Benefits Video: https://www.youtube.com/watch?v=MMPzsi1GkFI Publisher: Ethos Benefits Cite as: "Benefits Dirty Dozen, Part 2. Health plan tactics 6 to 1.," The Business of Benefits, Episode 89, Ethos Benefits, https://ethosbenefits.com/podcast/benefits-dirty-dozen-part-2, 2026-10-22. **Summary:** Employers can expose most hidden health plan costs by securing claim-level data and audit rights in their contracts. In Part 2 of the Benefits Dirty Dozen, the Ethos Benefits team covers cross-plan offsetting, commissions that rise with premium, point solution pile-ons, PBM compensation, voluntary benefits that fund free technology, and blocked data access. ## Key takeaways - Donovan Ryckis says a large agency's claimed buying power with carriers is never quantified, and Patrick Ansara describes cross-plan offsetting, where a carrier sets a revenue target and the broker decides which clients absorb the bigger renewals. - Chelsea Ryckis recommends lining up the last three renewals against the last three years of loss ratios and asking for an underwriting exhibit that shows how rates are built from the plan's own experience. - When broker compensation is a percentage of premium, the advisor earns more as the renewal goes up, so the hosts recommend asking for compensation in dollars, not just percentages. - Before adding another point solution program, Chelsea Ryckis suggests dividing each vendor's annual fee by the number of employees who actually used it and asking for savings measured against the plan's own claims. - Patrick Ansara says a PBM admin fee far below what other bidders charge signals revenue made up elsewhere, such as spread pricing or retained rebates. - The hosts rank data obstruction as the number one tactic, and Donovan Ryckis recommends negotiating a raw data feed to a third-party data warehouse the employer owns at every renewal. ## Chapters - 00:00 Cold open: renewals, PBM spread pricing and claims data (https://www.youtube.com/watch?v=MMPzsi1GkFI) - 01:12 Part 2 of the Benefits Dirty Dozen for health plans (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=72s) - 02:04 Tactic 6: Broker buying power and cross-plan offsetting (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=124s) - 08:07 How to check if your renewal reflects your own claims (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=487s) - 11:06 Tactic 5: Broker compensation that scales with premium (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=666s) - 16:18 When percentage commissions make sense for small groups (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=978s) - 20:22 Tactic 4: The point solution pile-on (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=1222s) - 26:44 How to measure point solution ROI (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=1604s) - 29:48 Tactic 3: Hidden PBM compensation and fees (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=1788s) - 37:35 Tactic 2: Voluntary benefits and free enrollment technology (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=2255s) - 44:22 Tactic 1: Obstruction of claims data and contract access (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=2662s) - 53:24 How to get claims data at renewal (https://www.youtube.com/watch?v=MMPzsi1GkFI&t=3204s) ## Quotes > There's probably not another professional that you can think of that you hire that gets paid more as the results get worse for you. Donovan Ryckis, Ethos Benefits > Nothing in life is free. Can we all just agree on that, please? Chelsea Ryckis, Ethos Benefits > This is a check register in your business, and it should be treated as such. Donovan Ryckis, Ethos Benefits ## In this episode. Employers that can see their own claims data, contracts and compensation in dollars are hard to overcharge. In Part 2 of the Benefits Dirty Dozen, Chelsea Ryckis, Donovan Ryckis and Patrick Ansara of Ethos Benefits work through tactics 6 to 1, finishing with the one they say makes the other eleven visible. Each tactic gets a fix and a verdict: dirty or dumb. The hosts are clear that commissions, point solution programs, PBMs and voluntary benefits all have a place. The problems they describe come from hidden pay and missing data. - **Cross-plan offsetting.** Agency claims of buying power with carriers, and why a renewal should rest on the plan's own claims and a written underwriting exhibit. - **Compensation that scales with premium.** Percentage commissions, bonuses and overrides, and why the [broker compensation disclosure](https://ethosbenefits.com/benefits-101/broker-compensation-disclosure) should show dollars. - **The point solution pile-on.** Programs added at each renewal that the plan's contracts disallow or that the population does not need. - **PBM compensation.** Per-script fees, retained rebates and [PBM spread pricing](https://ethosbenefits.com/benefits-101/pbm-spread-pricing), plus the questions to ask when [choosing a PBM](https://ethosbenefits.com/benefits-101/how-to-choose-a-pbm). - **Voluntary benefits and free technology.** Heaped commissions, carrier churn and the [fiduciary duty that can attach to voluntary benefits](https://ethosbenefits.com/benefits-101/voluntary-benefits-fiduciary-duty). - **Obstruction of data and contract access.** What real [health plan claims data access](https://ethosbenefits.com/insights/health-plan-claims-data-access) looks like, and how the [gag clause attestation](https://ethosbenefits.com/benefits-101/gag-clause-attestation) fits in. ## Related guides - [The benefits dirty dozen](https://ethosbenefits.com/insights/benefits-dirty-dozen) - [Broker compensation disclosure](https://ethosbenefits.com/benefits-101/broker-compensation-disclosure) - [PBM spread pricing](https://ethosbenefits.com/benefits-101/pbm-spread-pricing) - [How to choose a PBM](https://ethosbenefits.com/benefits-101/how-to-choose-a-pbm) - [Voluntary benefits and fiduciary duty](https://ethosbenefits.com/benefits-101/voluntary-benefits-fiduciary-duty) - [Health plan claims data access](https://ethosbenefits.com/insights/health-plan-claims-data-access) - [The gag clause attestation](https://ethosbenefits.com/benefits-101/gag-clause-attestation) - [Your health plan renewal timeline](https://ethosbenefits.com/insights/health-plan-renewal-timeline) ## Frequently asked questions ### What is cross-plan offsetting in health insurance renewals? Patrick Ansara describes it as a carrier giving a large agency a list of its clients renewing at a given time along with a revenue target, then letting the broker decide who gets the higher and lower renewals. He says an employer can end up subsidizing another client's renewal instead of being underwritten on its own claims. ### Does a benefits broker earn more when premiums go up? When compensation is a percentage of premium, yes. Donovan Ryckis explains that growth bonuses, persistency bonuses and overrides can add to it, and that broker disclosures often list these without quantifying them. Patrick Ansara walks through an example in which a 12 percent renewal raises the advisor's commission along with the premium. ### Are percentage commissions ever appropriate? Chelsea Ryckis says yes for some small employers, such as a 40-life company, where commission may be the only workable model, as long as it is disclosed. Donovan Ryckis adds that carriers often require a percentage for fully insured groups under 100 lives, so the employer should watch for commission creep and consider recalculating the percentage after a renewal increase. ### How should an employer evaluate point solution ROI? Chelsea Ryckis recommends listing every vendor and its fee, getting utilization data, dividing the annual fee by the number of employees who used it, and asking each vendor to show savings against the plan's own claims. Patrick Ansara suggests starting with utilization-based pricing when a vendor offers it. ### What are red flags for hidden PBM fees in an RFP? Patrick Ansara says an admin fee far below what more transparent PBMs charge means the revenue is coming from somewhere else, such as spread pricing or retained rebates. Chelsea Ryckis recommends asking the PBM in writing to define specialty and pass-through and to explain how rebates are handled. ### Who pays for free benefits enrollment technology? Chelsea Ryckis, who pitched free enrollment platforms in her first job in insurance, says the commissions on voluntary products pay for it. Patrick Ansara explains how heaped first-year commissions can lead brokers to move voluntary plans to a new carrier to restart the commission cycle. ### What claims data should employers get from their health insurer? Donovan Ryckis says employers should get claim-level accounting to the penny, not a few pages of summaries by condition. Chelsea Ryckis notes that member-level data needs a business associate agreement, a plan administration purpose and a secure place to land, and Donovan Ryckis recommends making a raw data feed a term of every renewal. ## Full transcript [00:00] Patrick Ansara: You can choose who's receiving the highest renewal or lowest renewal, and it really comes down to the broker understanding how much they can get away with rather than having it based on a data-driven decision. [00:12] Donovan Ryckis: Market leverage is fairy dust. It's completely made up. There's nothing to it. [00:17] Patrick Ansara: I'll tell you something, it's way more than the typical admin fee would be. So if you have that spread pricing in there, you want to get it out of there as soon as you can. But that's when the job actually starts. And that's how we view it too, is when the carrier or vendor tells us no, that's when we start to get to work. And I think as a plan sponsor, I would just say, hey, this is our data, give it to us. And if they're not willing to do so, then you know that that vendor is on the list to be marketed for the next year. [00:51] Chelsea Ryckis: The Business of Benefits is your no BS, no sales guide to real solutions. No gimmicks, just the truth [00:56] Donovan Ryckis: about how to take control, transform your benefits, and care for your most valuable asset, your people. [01:04] Chelsea Ryckis: If you're tired of the same old sales pitch and you're ready to rethink your benefits, this podcast is for you. The truth is out there. Are you ready to hear it? [01:12] Chelsea Ryckis: Hey everybody, welcome to this week's episode of The Business of Benefits podcast. Today is part two of the Dirty Dozen, our iteration on what the IRS puts out for taxes and little schemes that are happening. We're actually doing this for employee benefits, health and welfare plans specifically. So this was actually Donovan's brainchild. It's been really fun to put this together, the three of us. So what we're going to do today is we're going to go through numbers six through one. So without further ado, Donovan, you want to kick us off? [01:42] Donovan Ryckis: Yeah. So the Dirty Dozen, it is tactics and schemes, not necessarily illegal, but things that are getting abused and being done the wrong way essentially. And the IRS releases those every year. So to Chelsea's point, we're doing the same thing here for benefits. If you missed the last episode, go through that and you'll see numbers 12 through seven. [02:04] Donovan Ryckis: And today we're going to start with number six, which is something that is said by every large brokerage. On the face of it, it makes sense, but it's about market leverage and what that actually means, and more of what we see, which is cross-plan offsetting. So the idea here is that these large agencies go to employers and they say, oh, because we're so big, because we're such a large agency, we have leverage over the carriers, and that's going to allow us to get a better renewal and a better outcome for you. And on the face of it, it kind of makes sense. But that leverage is never, ever quantified. And it's because it doesn't exist. So this is something that could absolutely not be said in securities, because the data exists to prove or disprove a statement like that. Whereas in insurance, the data doesn't exist. We all know in health and welfare plans, data is always being hidden and reported in creative ways to not give full transparency and audit rights to plan sponsors. And what we really see is that the leverage is actually more so for the brokers and the agencies in their book of business bonuses, their bundles, their proprietary contracts, their PBM collectives, which we reviewed. And it doesn't actually get to results. And when we do quantify it against even just the open market, what a plan sponsor could get on their own, it doesn't even match up to that, basically. [03:46] Patrick Ansara: Yeah, and I think it can cost you a lot, because you are subsidizing, in the situation of cross-plan offsetting, someone else's renewal. At the end of the day, you want to make sure that you're getting all the data you can so that you can verify that your renewals are justified in what's being presented, and it's not something that's being offset from another client, or you are not subsidizing another client of theirs. [04:11] Donovan Ryckis: So can you explain that? Because everybody that has joined our agency has come from larger agencies, and all of them have shared this experience of having a vendor come to them and offer basically cross-plan offsetting. So can you describe what that process is and how you've seen it? [04:31] Patrick Ansara: Yeah, essentially when an agency is doing a lot of business with one particular carrier, a lot of times what that carrier will do is give them a list of their clients who are renewing at a particular time and say, hey, this is the amount of revenue we need. You can choose who's receiving the highest renewal or lowest renewal. And it really comes down to the broker understanding how much they can get away with, rather than having it based on a data-driven decision. [04:58] Chelsea Ryckis: Which client is going to swallow the highest increase? Who can you pass 12 off to? It's crazy. [05:04] Patrick Ansara: Exactly. It makes no sense when it comes down to an underwriting perspective, because you should want your underwriting to be based off of your actual claims and not somebody else's. And I think that's the biggest thing to look out for when looking at any of these contracts that you're going through. And we talked about this in our prior episode, which is reviewing those contracts for those cross-plan offsetting terms. [05:26] Donovan Ryckis: And I think everybody can agree with this, anybody that's been in the business. When these renewals are brought to you, even if it's just on a one-by-one basis, not even on a quarterly basis like what we're talking about, the question from the vendor or the carrier is not about the data. Literally what they say is, what will they take? So it's more of a tolerance of what the broker thinks that particular company will accept or not accept. Not being a data-driven decision. The data is almost stripped away and the carrier's saying, we want this. What will it take? What will they accept? And then that's where this cross-plan offsetting comes into place. So if a broker has a client that's in a more difficult spot, they've swallowed a bunch of increases, maybe they think they're on the verge of getting fired on that one, versus another one they know they're locked in, they had an okay year last year, they'll kind of move over that increase to another client. [06:31] Patrick Ansara: Yep, exactly that. [06:32] Chelsea Ryckis: Manipulative. [06:33] Patrick Ansara: I think that also comes down to the whole market leverage conversation. These are all connected. Market leverage versus cross-plan offsetting. It comes down to that leverage that agency is saying that they have with that particular carrier. We do so much business with them, we're going to save you a ton of money. But it doesn't always pan out that way. [06:53] Chelsea Ryckis: Okay, so devil's advocate, because that's my awesome role in this show. I think it's fair to say that relationships will get you faster service and possibly some underwriting flexibility or some favors here and there. But at the end of the day, plan sponsors should want a plan and rates that are based off of their own risk. That's the only way to really manage, because you can't guarantee these behind-the-scenes deals every single year. And again, most of the time they don't actually work in your favor. I'm thinking of another situation on the relationship side where we were brought into a client and they were like, oh, well, we have a relationship. There was a new person brought into the company. They have a relationship with the incumbent brokerage and they were going to get the A team now, because apparently they had the C or D team. Which is a whole other thing. Why do you have C and D teams? But nonetheless. And then they got the A team because of the relationship, but it wasn't actually different, right? In terms of strategy and moving the needle, because the business model of that brokerage was the problem. It wasn't the service team, that oftentimes has to wear a lot of the negativity that's actually a result of the business model, not the service team. [08:07] Chelsea Ryckis: Okay, so what can plan sponsors actually do? The recommendation here is just check. Line up your last three renewals against your last three years of loss ratios and check if they're moving together. And then ask for an underwriting exhibit. Get it in writing, how your rates are actually being built, and make sure that it's on your plan's experience. [08:27] Patrick Ansara: And I'll just add one thing to that, because we just came across this. Asking for the underwriting exhibit is a huge win for you if you can get that information. We just came across this with another client and we found out that on their plan, the carrier wasn't even factoring in all of the rebates that they were receiving on the plan into their loss ratio. So that was grossly inflating their actual loss ratio overall, where we were able to get that dropped down by about 10 percent in the overall renewal by having that factored in. [09:00] Chelsea Ryckis: Crazy. [09:00] Donovan Ryckis: That's a great point. Stuff like that happens all the time. And I think if you're signaling that you are almost certainly going to renew, they'll probably push back on that underwriting exhibit. If you string them out a little bit, act a little unsure, I think you'll get it and then you'll have some better data to make a decision. [09:16] Chelsea Ryckis: All right guys, dirty or dumb? Okay, dirty. If you guys disagree with me, I'm going to be annoyed. [09:22] Patrick Ansara: No, 100 percent. This whole market leverage talk and cross-plan offsetting is a dirty trick. At the end of the day, it's not aligned with the client, so it's a dirty trick. [09:33] Donovan Ryckis: Yeah. Market leverage is fairy dust. It's completely made up. There's nothing to it. And even in the cases where potentially they have a little bit of a better plan with a vendor, it is still a worse plan than all the other vendors in the open market. I've learned this on all lines of insurance, all securities. The best products pay the worst commissions across the board, whether we're talking about securities and mutual funds, or we're talking about Medicare supplements, life insurance. That's just how it exists. If you have the best plan in the market, you don't have to pay the best commissions. They will pay the lowest commissions. And that exists very much for everything in a healthcare plan as well. So if there's a claim to market leverage, prove it. Show me where, how. [10:37] Chelsea Ryckis: I think my biggest takeaway on a personal note from this section is that fairy dust is a way to explain market leverage, because I was in a meeting yesterday with Patrick and I was... [10:48] Donovan Ryckis: It's wuzzy. [10:51] Chelsea Ryckis: My go-to, and I need to change this, is that it's BS or that it's smoke and mirrors. And every time I go to say it, I'm like, don't say BS. Don't say BS. But I think I'll stick with fairy dust now. [11:03] Donovan Ryckis: All right. Number five. [11:06] Chelsea Ryckis: Compensation that scales with your premium. So this one's near and dear to all of our hearts here. Basically your advisor will get a raise every time that your renewal goes up. And I guess the question is, how often does your renewal go up? Probably pretty often, right? Donovan, you want to break it down, what it actually means? [11:23] Donovan Ryckis: Yeah, pretty straightforward. And this still exists for the majority of plan sponsors. So any compensation that is structured as a percentage of premium. This is more problematic in the health space rather than the voluntary benefits lines, because obviously we have a much bigger problem with medical inflation in healthcare plans than those voluntary lines. So those are a little bit easier to market. They typically don't see the same type of increases. When they do, the data is readily available to make those decisions. And also a lot of voluntary vendors will not structure flat fee compensation on those. So that's just how that side exists, unfortunately. So in addition to percentage of premium as a compensation schedule, we see growth bonuses, persistency bonuses. So they get paid more as the premium grows, as they retain clients with that carrier regardless of those increases. And then the things that plan sponsors never see, which is additional bonuses and overrides, which they really should be getting as part of their 408. You'll see this listed out on the broker's own provided compensation disclosure as "we may receive additional compensation," and they'll kind of just briefly lay it out, but they never ever quantify it, which is something plan sponsors certainly need to push back on. [12:51] Chelsea Ryckis: I haven't got to tell you guys this because it literally happened yesterday, but I was reviewing a compensation disclosure for a new prospective client. And it literally says in it that we will not go to market and look at any carriers other than the incumbent unless you specifically ask. It just says it in there. [13:10] Patrick Ansara: That's incredible. [13:11] Chelsea Ryckis: Yeah. And then it discloses a 1 percent override bonus, I think 4 percent on premium, and then another retention bonus. It discloses the percentages, obviously not the dollar amount, which is what we'll get into here being a problem. But how interesting. You have to ask, otherwise we will just continue to show you the incumbent year after year. [13:31] Patrick Ansara: Yeah, that's crazy to even have something like that in there, and it makes no sense. [13:36] Chelsea Ryckis: Well, I think it's related to this, which is basically because this specific carrier, their trend has been double digits every single year. Compensation is obviously scaling with that premium. Why would they, right? [13:49] Patrick Ansara: They might as well just state, we won't help you fulfill your fiduciary obligations as a plan sponsor. That's a better way to put it, I guess. [13:56] Donovan Ryckis: Or like an away email message. We're only working if you ask us to. [14:02] Chelsea Ryckis: If you think we're getting fired, actually. [14:04] Donovan Ryckis: I'm on vacation right now. Unless you need something, I'll think about it. [14:09] Patrick Ansara: Oh, that's amazing. Well, it can cost a ton if you don't actually look at what these numbers come out to be. And with that compensation scaling with your premium, it makes a big difference, because the advisor is literally incentivized to not lower your premium. So let's take an example. If you have 500 employees on your plan and your per employee per year cost is around $12,000 a year, you're looking at a figure of around $6 million. And let's say that advisor is achieving a 4 percent commission on that. That's $240,000 per year. If your renewal goes up 12 percent, which is pretty common, we see that a lot especially on a fully insured plan, that goes up from $6 million to $6.72 million, meaning that advisor is now earning $268,000 in commission. So the plan got $720,000 worse, and the advisor got $28,000 better. If you have a flat fee built in there, that's not moving. So you can be assured that your advisor is aligned to lower your premium because they're working for that flat fee. [15:20] Chelsea Ryckis: This example didn't even include bonuses, et cetera, for growing the book of business with that carrier, right? [15:27] Patrick Ansara: Yeah, exactly. So there could be a lot more compensation on the back end that isn't even reflected in that. [15:33] Chelsea Ryckis: This kind of reminds me, Patrick, of a conversation we had yesterday with a new client going through their renewal, transitioning from fully insured to level funded. They, a couple years ago, were told by their incumbent, a top five largest agency, that moving to fully insured would be less volatile and they could have better prediction and control over their spend under the fully insured chassis. So they listened to them because they were scared of rising healthcare costs, moved to fully insured, where they essentially lost every piece of data that they had and got hammered with a huge renewal increase, almost 50 percent. So yeah, good times. [16:18] Chelsea Ryckis: Okay. So how about when this actually is legit? And I'm thinking small market. I'm thinking like a 40 life company that maybe can't stomach a $60,000 flat consulting fee. Sometimes commissions is the only model that works for them. So this isn't to say that commissions are all bad. It's just to say that if you are in that model, you want to understand how it works. You want to have it disclosed. If it's undisclosed and unquantified, that's when I think it's dirty and it's bad. [16:51] Donovan Ryckis: Yeah, it's a good point. If you have under 100 lives on plan, if you're fully funded, likely those carriers force a percentage, but that percentage can change each year. So it's important to just watch that creep of commissions. What you could do is calculate it to a flat fee, and if you get a 12 percent renewal, recalculate that percentage to keep it flat. Because the question is, did the scope of services from the agency increase for you guys as a company? And if not, then perhaps they don't deserve an auto escalation on their compensation year after year after year. Maybe they do, but we need to know. [17:36] Chelsea Ryckis: Yeah, I think the other key point of what Donovan just said is the fact that compensation is a conversation, and plan sponsors oftentimes don't realize that it can be different than what it is. Actually, I would say 90 percent of the plan sponsors that we speak to have no idea what they're paying or that they could ask for something different. If an advisor is wishy-washy about their compensation, or they can't explain it, or they get kind of odd or weird, that's definitely a red flag. But I would say plan sponsors, if there's an action item for you in this one, it's finding the compensation disclosure. So number one, making sure you have it. Is there a dollar figure attached to it, or is it just showing a percentage? Because if you see 2 percent, 3 percent, it doesn't sound like a lot. But on a $10, $15, $30 million spend, that's significant. So you want to see an actual dollar amount attached to it. And here's the deal. They may say to you, well, we don't know what the enrollment is going to be. Okay, project off last year, or give me an updated one once we get through open enrollment and you have your final numbers. Show me what this actually looks like in a dollar amount. [18:47] Donovan Ryckis: Yeah, I think the ending note on this is pretty simple. There's probably not another professional that you can think of that you hire that gets paid more as the results get worse for you. So that's the spirit of it. [19:01] Chelsea Ryckis: All right. So dirty or dumb for percentage compensation? [19:06] Patrick Ansara: I would say it's dumb in most cases. There's situations where it can make sense. [19:18] Donovan Ryckis: Yeah, I agree. We can't say it's dirty because the small market exists that way. A lot of fully funded carriers, depending on what state, what carrier, will only operate that way. I think it's mainly dumb, but certainly agencies have profited off of this. So there is a spot in it for dirty. I've shown groups on our first conversation or two their last five years' 5500s and how the broker compensation in parallel scales with their premium, and they're always surprised to see that. So I think it's a little bit dirty in the sense that if we're following the CAA and providing 408s before plan sponsors enter into plan decisions, they would see that. So any conversation that's being withheld, or that we're kind of skirting past, I think has an element of dirty. But overall, this is a dumb tactic. [20:22] Chelsea Ryckis: All right. Number four. So this is the point solution pile-on. And what this looks like is every renewal comes with something new, something shiny, maybe a navigation app, an MSK program, a diabetes platform, but nothing ever comes off. So we're just throwing more things at the wall to see what sticks. [20:38] Donovan Ryckis: Yeah, there's a lot. I've seen some new stuff this year that I wouldn't have expected, that we wouldn't have seen from the large legacy agencies in prior years, but they were done completely incorrectly, in a way to pacify the plan sponsor that something innovative was happening. So a really great example is a plan sponsor on a fully funded BUCA plan with a PBM that expressly disallows any solution that is not within their network. And the brokerage added an international pharmacy, which means it's not going to be communicated through the plan. So if an employee fills a drug that is available for international sourcing, they're not going to get a notification. It's not going to count towards deductibles and accumulators, and to your specific deductible for the plan, or your claims. So basically what they had is they had a bunch of opportunities that they saw at the end of the year for people to use this. And they're like, well, nobody's using them. Why is nobody using it? And it's like, well, because it's not allowed. It's not integrated. It's not communicated. It's not calculated. And we've seen a lot of that, where these solutions are getting placed in to basically have a perception of innovation and change, but there's nothing actually there. [22:09] Chelsea Ryckis: I have another example just recently. A vendor for basically sourcing autism providers easier, faster, whatnot, reached out to me. They had met one of my plan sponsors at a conference. And they were like, they absolutely need this. They need this so bad. They need it right now. And I had our account executive look at the data and we don't have a single claim for this company for that point solution. And I was like, hey, what made you think that? He also, when he reached out, he was nicknaming the plan sponsor and stuff. And yeah, no, there was not a single claim for this on this particular health plan. But it was obviously the biggest thing for us to focus on already when we started. [22:55] Patrick Ansara: And I think when you look at that, you have to understand what's going on with your data to really understand what solutions you need, and not just try to bolt on solutions that you think may help without knowing if your population actually needs it. So relying on things like your benefit surveys to understand what are pain points for your employees, or what's actually happening from a claims perspective, will help you understand what you actually need in your health plan. But you look at a bunch of different point solutions that are being offered, and if each one is, let's say, four dollars per employee per month, another $144,000 a year on a 500 life group. So I think the important thing here, when you start bundling in all these different point solutions, is making sure that they're playing well in the sandbox together. Because you might start adding on solutions that are already being tackled by another vendor. And then you have these competing point solutions in your plan and it's like, who's handling what? And it creates confusion for the plan and for the employees and members on the plan as well. [24:00] Chelsea Ryckis: That's one of the reasons too, where if we have a relatively heavy point solution client, we will have what we call vendor summits. And if anyone's going to UPower this year, we're hoping to talk about that at UPower, or next year. The entire point is what Patrick says. You're bringing everybody together and you're looking at all these solutions, and you're looking at the pathway of care for an employee and like, where are they going to overlap? Where are they going to be confused? Where is it going to cause friction? And how are we going to handle this behind the scenes? So that's super, super important if you do have a plan with a lot of point solutions. But before you get to a plan with a ton of point solutions, to everybody's point, is it really needed? Donovan, did you mention that there's sometimes compensation in these plans as well for advisors? I don't even think you said that. [24:47] Donovan Ryckis: It's honestly something I forgot, because we obviously just go flat fee for the whole healthcare plan. Whereas typically brokers, even when they do the right thing and they're doing a PEPM instead of a percentage, then there'll be something in the PBM, then there'll be something in the stop loss. So I think it's also misleading, because plan sponsors are led to believe, hey, this is my flat fee for the healthcare plan. And then they find out there's actually a buck in everything. Like even FSA vendors, they'll often be 25 cents, 50 cents a month for having that FSA. So yeah, compensation can be built into every single one of these lines, which is often another reason they're suggested. I think years one through three of innovating on the healthcare plan really should be focused on the highest ROI levers, not the cool widgets and additive point solutions yet, unless you already have a good download of prior year's data. If that doesn't exist, if it's not understood, it should really be the highest ROI stuff first, and then looking into these point solutions after year one or year two. [26:05] Chelsea Ryckis: There can be times though, guys, where this point solution, it's not like the plan sponsor is necessarily looking for a direct ROI, or the expectation isn't that it's to pay for itself. It could only be for recruiting and retention. I'm thinking like fertility benefits or adoption assistance. For certain younger, a lot of male-dominated companies, that's incredibly attractive from a loyalty standpoint. So I would just caveat that there might be other business needs that drive some of these decisions. [26:42] Patrick Ansara: Yeah, totally agree. [26:44] Chelsea Ryckis: So I think for plan sponsors, list every vendor, look at the PEPM or however it is that you're paying for this, next to each. Get some utilization data. There's actually some vendors out in the space right now that are compiling all of this information into dashboards and obviously using AI. If you have a good data analytics platform, you could probably do that too. But divide the annual fee by the number of employees that actually used it to see what this is looking like. And then ask each vendor to show savings against your claims. Sometimes those proposals can be a little tricky because they will formulate it in a way that is advantageous for them. So just understanding how they're coming to those ROI numbers is really important. But this isn't to say that point solutions are bad in any way. It's just, again, the ones that we have, are they impacting our highest claims and actually driving cost down, or meeting another business need? [27:44] Patrick Ansara: Yeah, and one other thing I'd add to that. A lot of these types of point solution vendors will have two types of fee offerings. Sometimes they'll bill it as a PEPM, and sometimes it's utilization-based. And starting at that utilization basis gives you the opportunity to test that vendor out, make sure it makes sense for your population, and make sure that you're only paying for when you're using them. So I think that's another caveat to add on to this too. [28:10] Chelsea Ryckis: The last thing, I promise, would be looking at utilization data. And then also, if you're doing an annual benefit satisfaction survey, what is the perception to employees and what is the utilization? That's really interesting to look at, because if the utilization is low and the perception of value is low, then what are we doing here? Reallocate those dollars, right? [28:30] Patrick Ansara: Exactly. [28:31] Chelsea Ryckis: Dirty or dumb, folks? [28:32] Donovan Ryckis: This is a tough one. There are circumstances where it could be both. I think it is both a little dirty and dumb to integrate point solutions that are expressly disallowed in your ASA or your ASO agreement. That's pretty dumb. I think it's dirty to add compensation to every line and then not disclose them, which is done very often. So I think that's all I really have to say about dirty and dumb. But obviously, point solutions, they exist for a reason. They're really beneficial. A lot of our plan sponsors have them. They perform really well. It's just making sure there's an understanding of the ROI, the cost structure, the fee structure, to really judge if that point solution has a place. [29:23] Patrick Ansara: Yeah, agreed. I don't think it's necessarily dirty. I think the dumb piece comes down to just bolting on any solution you come across without doing the proper evaluation to see if it's a good fit, and if it's something that the plan participants actually need. That's the only dumb part about this. But like you said, Donovan, there's a ton of really good solutions out there that can be utilized to improve the overall health and welfare plan. [29:48] Chelsea Ryckis: Data-driven decision-making. It's a powerful thing. Number three, PBM compensation. So this would be, you've never actually seen a dollar figure for what your PBM makes on your health plan. [30:01] Donovan Ryckis: Yeah, so there's all kinds of additional fees in PBMs, and I think most plan sponsors rightly assume it's just part of the health plan and don't understand there's additional fees. So there's per-claim fees or script fill fees, where a broker could actually be getting paid as much as, I think the highest one we've seen is $2.75, every single time an employee, a spouse, or a dependent fills a prescription. There could be, back to the collective agreements, where the agency actually has a share of the profits with that PBM. There's rebate retention. There is additional PBM admin fees that are sometimes built in. So there's all kinds of tactics and strategies here. This is also covering one of the ones we did on the last episode, which is PEPM turning into PMPM. So turning a fee that's listed per employee, and then when we get to the contract, they flip it and switch it to per member, which is about a 2.4x multiplier for a one-letter change. [31:17] Chelsea Ryckis: Donovan, one of the first self-funded health plans that you took over from somebody else, not the first ones that you... [31:22] Donovan Ryckis: Gosh, that was crazy. [31:23] Chelsea Ryckis: Okay, but wasn't it a $7 per script fill fee? You just said $2.75. I'm like, no, we've seen $6. We've seen much higher than that. Maybe not in the last five to seven years, but... [31:36] Donovan Ryckis: Yeah, that was like 11 or 12 years ago. And that was so hard to unwind. What had happened was... [31:50] Chelsea Ryckis: This starts off a good story. [31:52] Donovan Ryckis: Yeah, this is the wildest one. And what an intro to self-funding. What had happened was that the broker, with the PBM agreement, set up a deal with a local pharmacy. So all employees had to fill with this one pharmacy, which I don't know how that was approved, because they didn't all live there. So it was a pain. Everybody hated it, and the broker was basically getting kickbacks on the total fills and the revenue coming in from all the fills. And it was this weird structure where the pharmacy was invoicing the broker, and then the broker was invoicing the plan, but was not providing any accounting. So they would just send an invoice with basically, all right, July, $17,000. But yeah, that's how wild PBM agreements can get, where the broker was essentially allowed to tap the plan for whatever he wanted and there was no corresponding claims data to follow. So no deductible accumulators, none of that was calculating towards spec for the plan sponsor or aggregate claims. [33:11] Patrick Ansara: That's one of the craziest things I've ever heard. [33:15] Donovan Ryckis: And that's self-funding. I was like, what the hell is going on? Well, what happened was the pharmacy called me and was asking me for money. They're like, where's my payment for... And I was like, why? I'm not paying you. Why would I pay you? Yeah, it was wild. Anyway, moving on. [33:36] Patrick Ansara: Yeah, well, I think the biggest thing when you look at PBM compensation overall is you have to look at what's happening in the contract to really understand what your plan is being charged. And so I think one of the key red flags you can look out for is when you're comparing PBMs or you're doing a PBM RFP. If all the other PBMs have one fee as their admin fee, the more transparent PBMs, and you look at some other PBMs and theirs is a fraction of that, maybe 90 percent less, then you know that there's going to be some additional fees somewhere. They're making that money up from somewhere. And so that's where you get into the contract and you can see, do they prohibit spread pricing, or are they retaining a portion of rebates? All of those things are additional revenue. So getting down to the actual dollar figures, where they receive their revenue stream from, is key in any PBM compensation contract, because we see so many different strategies that some of these PBMs try to implement. [34:35] Chelsea Ryckis: I think it's important to note that PBMs are necessary. They do real work. They have networks and adjudication in real time, clinical programs. The rebate negotiation would be really tough for an employer to do, or even brokers. So there's good work being done. The problem is the opacity. It's not that there's actually a middle entity there. It's just the fact that it's so confusing and oftentimes hidden. [35:03] Patrick Ansara: Yeah, I think one thing I'd point to as well. North Carolina has a rule where PBMs have to disclose their spread pricing. And we were able to see exactly what that spread is. And I'll tell you something, it's way more than the typical admin fee would be. So if you have that spread pricing in there, you want to get it out of there as soon as you can. [35:24] Donovan Ryckis: Super cool to see. That was a great report. [35:27] Chelsea Ryckis: So ask your PBM in writing for the definition of specialty in your contract. Ask them what exactly pass-through means. Ask them how the rebates are being handled. Even if you think you know, ask it in writing as well. And then try to do a flat fee, a PEPM fee, as opposed to allowing the spread pricing and all these other things that are going on behind the scenes to exist. I remember, Donovan, we used to have a slide in one of our discovery presentations that was like 49 ways a PBM hides money. Do you remember that? [36:00] Donovan Ryckis: Yeah, there's a lot. I think it was 47 or 49. [36:05] Chelsea Ryckis: Spread is one. That was my point there. All right guys, dirty or dumb? [36:10] Patrick Ansara: Dirty in most of these cases. I think most of the PBM contracts we come across, especially in our RFP process, because when we go through that, we're requesting the contract first and foremost, because that's going to tell us whether or not this is a good PBM that we would want to further the conversation with. And that's where we see so many dirty tricks. And what's funny is we request the contract and we send them a questionnaire, and the amount of times that the questionnaire we sent them doesn't line up with the contract is almost 100 percent. So we always find little discrepancies between what they tell you versus what's actually written down. [36:46] Chelsea Ryckis: So funny. [36:47] Donovan Ryckis: I think overall PBM practices, we've seen so much stuff. Whether we're talking about all the fees from brokers, all the fees from PBMs, the collective agreements from brokers and agencies, gosh, even some of the PBM consultants, which I think could have value in some places, just not for us. We were not impressed with the thoroughness of the process, and they were taking back lifetime fees once they got set up. So PBMs in general is just one of the dirtiest places in healthcare plans. It's also the easiest to fix. [37:29] Patrick Ansara: Yeah, and there are good ones. [37:32] Donovan Ryckis: There's a lot of them doing it right. [37:35] Chelsea Ryckis: So this next one, number two, voluntary benefits and your free benefits technology. I think I'm the perfect person to explain this, because this was literally my first job in insurance. So when I first came into insurance, I was with [company removed], and [company removed] is a great carrier. But literally, this was my pitch. And this is actually how I met Donovan, if anybody wants to know. I went to Donovan and I said, hey, I can be your enrollment team. I have an enrollment platform that you don't have to pay for. I will do all the one-on-ones and counsel all of the employees. And it's free. Enrollment support is free. The technology is free. And everybody's happy because it's free. So essentially, the way that this happens is that the commissions on those voluntary products are what's paying for all the free things. Nothing in life is free. Can we all just agree on that, please? So the counseling is a sales conversation. And unfortunately, even though there is value in one-on-one consultations for sure, it goes back to the first one we talked about today. If that sale is tied to a commission, that person can maybe position those products a certain way or be pushy. And you really want to have unconflicted advice in those one-on-one scenarios. So where loss ratios are low, employees end up paying far more in premium than they actually get back. And that's the difference ultimately that's going to pay for the employer's technology. [38:58] Donovan Ryckis: I'm going to focus on the voluntary benefits side, because we've seen so much action on that this year because of the variability of that compensation. It is insane. We're seeing a lot more contracts with heaped commissions. So that's contracts that are first year, and the compensation can be as much as 60 to, I think we saw one this year that was like 87 percent commission. So out of every dollar, 87 cents is going to the broker or the agency. Just insane. And we've seen a lot of litigation this year. So I'm just going to name a few. [company removed] and [company removed], 36.7 percent of premiums on average, peaking at 62.8 percent commission. [company removed] and [company removed], [company removed], 39.8 percent. [company removed], [company removed], about 36 percent. [company removed] and [company removed], [company removed], 33.5 percent. [company removed], it's [company removed] there, 28 percent. [company removed], [company removed], 22 percent over 10 years. [40:06] Patrick Ansara: It's wild because nobody's really monitoring this, because it's voluntary benefits. It's employee dollars. And so a lot of times the employer isn't even knowing that they need to search for that. But that's the importance of getting that compensation disclosure, that 408 compensation disclosure that has the details on there. So you have full visibility into that, because you shouldn't want your employees getting ripped off too. [40:30] Donovan Ryckis: Yeah. And these lawsuits are going to the employers and the brokerage as ERISA lawsuits, because they kind of miss two things. One is that the employer was receiving something, which is usually like a discount on the healthcare consulting fee, which is maybe where the plan sponsor was focusing. So what the brokerage did was shift it over to the employee dollars. So now the company is receiving a benefit from the employees' overpayments. [41:00] Chelsea Ryckis: Yeah, which violates the safe harbor and makes it an ERISA plan. [41:03] Donovan Ryckis: Correct. [41:04] Chelsea Ryckis: So the only time that I think this makes sense, having the one-on-one enrollments and maybe the technology for free. I want to say that in the smaller market, that can be very valuable, because some technology can be pretty expensive for smaller brokerages to handle that monthly fee. Smaller employers may not want to pay for something like that. So that could work. There is also value in one-on-one consultations. Sometimes some advice is better than no advice. The real question here though on the technology side is just that none of that requires compensation to be hidden. So just be upfront about it like everything else. In terms of voluntary benefits specifically, I think there's also merit in voluntary benefits like a hospital indemnity plan. And actually we used to do this a lot when we worked in the small market, like putting a hospital plan with a disability plan and having sort of a makeshift disability program for employers who didn't have leave. Or if the employer couldn't have a real maternity policy. So there's definitely ways that these programs are super, super valuable. It just comes back down to the incentives that are attached to it. [42:18] Patrick Ansara: Yeah, couldn't agree more. I think the incentive part is going to be the dirtiest piece about this, because it's hidden. And generally it's heaped a lot in those first year or sometimes two years, where you have a ton of the premium actually just going right back to the broker rather than... [42:38] Chelsea Ryckis: Can you explain though to plan sponsors why that's important? Because I've had so many conversations where we see this heaped compensation and then they say something like, and then we had to change carriers because the rates got out of control. But I don't think that they understand the link between heaped commissions and churning to another carrier. [42:56] Patrick Ansara: Well, that's the strategy that a lot of brokers will employ, which is, hey, we get heaped commissions on this, 50 percent first year, 30 percent second year, and then it's 5 percent every year after that. But then year three comes along when it's going to be 5 percent, and they say, hey, we need to switch this to this carrier now, and that carrier is just going to restart that same commission cycle. And then year three comes, same thing again. So 50 percent, 30 percent commissions year after year is what ends up getting paid to that broker. [43:28] Chelsea Ryckis: Yeah, dirty all day. Donovan? [43:33] Donovan Ryckis: Yeah, dirty. It's very easy to benchmark compensation on these voluntary plans, because they're a lot more straightforward. The services are more straightforward than a healthcare plan. So that data exists. And what's wild is for these companies we're seeing, these large ones in these voluntary lawsuits I just mentioned, [company removed] and [company removed], [company removed]. These are companies with 100,000-plus employees. So a reasonable compensation would be somewhere between 2 percent to 6 percent, and all of those were averaging like high 30s, most of them. Yeah, dirty, man. [44:22] Chelsea Ryckis: I'm kind of sad that we're at number one. This has been so much fun with you guys that I personally don't think I'm ready for it to be over. [44:29] Donovan Ryckis: So we'll do a new Dirty Dozen in January. [44:34] Chelsea Ryckis: Okay. There you go. So the last one, this is my personal favorite. Obstruction of data and contract access. So what this looks like is, you ask for your claims file or for your executed contract, and you got a summary, a delay, or a reason, aka an excuse. [44:55] Donovan Ryckis: Yeah, all of those things. So you ask for the data, maybe you get a summary. Maybe they say it doesn't exist. It gets fed up the chain and then pushed back, and then you get busy with something else. Sometimes the obstruction is the broker. Sometimes it's the contract that the broker brought to you that doesn't allow those kinds of things. Sometimes it's the carrier and just the strategy you're working with that you need to pivot. But we see this all over the place. I've seen it even where we have carriers that might provide like five pages of health plan data, and then the broker only provides one of them to the plan sponsor. So it's obstructed on both sides. Five pages is not comprehensive enough for a 500 life group, but then we find out they're not even passing all of it through. I had a really fun case where I was actually able to obtain the four missing pages essentially, and be like, hey, you've been missing these for every year, just so you know. [46:00] Chelsea Ryckis: Can we take a pause for a second and explain to plan sponsors? Because I can't tell you how many groups in the 1,000 to 10,000 space even that I'm speaking to that say, oh yeah, we have claims data. And then I'm like, oh yeah, tell me about it. And it's five pages, or it's a quarterly report from the carrier. What do we mean when we say data access? [46:24] Donovan Ryckis: Yeah, we mean actual accounting. So that's to the penny. This is a check register in your business, and it should be treated as such. And you should understand not only where the money went, but for what purpose. What was the CPT code? What's going on here? And that's the only way we can gauge reasonableness. So often plan sponsors' idea of data is, well, we spent $1.8 million in cancer, we spent $900,000 in NICU. It's like, well, that's not data. That's not what we need. We can't benchmark. We don't know if that's reasonable or not. So full accounting. Thoughts, Patrick? [47:10] Patrick Ansara: Yeah, one of the things I'm thinking of is just seeing some clients who are maybe with a fully insured carrier and they get their renewal letter and it says, hey, you're receiving a 40 percent renewal. And their justification for that is the two claims on the next page that they send over that says, oh, you had two high-cost claimants, but there's no other information that actually tells you what's happening behind the scenes. So they're just pointing out the worst cases and not talking about everything else that's happening. So I think when you talk about that obstruction of data, you're obstructing the decision-making process that a plan sponsor actually has. So you always just want to make sure that you're getting as much data as you can, and negotiating that before you sign that initial contract with that carrier or vendor. [47:57] Donovan Ryckis: I think anytime you're looking at claims as conditions rather than actual claims, there's a problem. So if your claims data is summarized exclusively to conditions, that's not going to be sufficient to get what you need to get an understanding of where the risk lies in your plan, and what solutions you might need, and how reasonable these reimbursement rates are, the compensation and the fees and all that kind of stuff. It should really be on a claim basis instead of just talking about conditions within your healthcare plan. That can be part of a summary, but the details should go to claim by claim, not exclusively like, here's your condition. [48:40] Chelsea Ryckis: So this is real leverage. Having access to the penny accounting, to your claims data, having a contract that allows you to have access to it, audit it, et cetera. That is real leverage. Not my broker's big, or my broker has a platinum status with Blue Cross. There's a huge difference there. I think the thing that I normally hear when I gently suggest that five pages may not be quite enough, especially under the CAA with gag clauses and also a risk of fiduciary duty, I always get hit with, well, there's PHI, or HIPAA, or something like that. And yes, member-level data will need a BAA and a plan administration purpose and a secure place to land. But granted, all of those things are true. We literally do this every single day compliantly. And I'll tell you, Patrick and I are dealing with it literally right now. We have one plan sponsor that we just took over that's fully insured. Underwriting methodology is unclear. There's no insights, no data access, no nothing. That's actually the example he just used. You have two high claimants on one page and that's about it. Versus we're working another renewal where we have a raw data feed, our data analytics platform, and we know exactly the business plan that we're going to create, go to market with, to ensure that their renewal doesn't suck this year. That is leverage. [50:06] Patrick Ansara: And I think, talking to that point too, Chelsea, when you have that data, you're able to see, okay, is this high-cost claimant an ongoing risk, or is this something that's really not going to be an issue next year? Maybe that individual is no longer with the company, or their prognosis has gotten better. But without knowing that, you can't properly underwrite for it, so you can't make a really good decision on it. [50:28] Chelsea Ryckis: Not to mention, on these fully insured reporting decks, you're seeing data that's eight months old, maybe. And you have absolutely no idea, to your point, if that risk even still exists or what it looks like today. Maybe that drug stopped. [50:45] Patrick Ansara: Yeah. So I think when you look at this overall, you really just have to focus on getting as much data access as you can and making sure you have all the proper audit rights. All these 12 things that we've talked about today all come back to this one key point, which is you need to get data and you need to have the proper contract terms in place to allow you to access that data and make better decisions. So without that, all these other 12 points kind of fall through. So this is definitely number one in my books. [51:14] Donovan Ryckis: Yeah, that's exactly where I was going to go with it next, is that you could solve one through 12 of the Dirty Dozen if you take care of number one. Right now there's no more vague terms of leverage. We understand compensation, we understand claims and renewals and going to market. Everything becomes clear. And furthermore, once you have this level of claims data, any renewal presentation that comes to you, there should really only be one question. The point of the renewal presentation should only be, how are we going to reduce the frequency and severity of claims? And here are our claims. And if the renewal presentation is divorced from that idea, you're not going to get anywhere. It's just a hope and pray. Okay, this carrier is going up, so we're going to drop you with this carrier. You're going from problem to their proposed solution, but no resolution in the middle. It's just kind of a hope. [52:12] Chelsea Ryckis: We were told yesterday in a renewal presentation with a new client, it was their executive board we were meeting with, and the CFO said, this is the most productive conversation we've had on health insurance ever. And this is a really well-established company, really bright folks leading it. And it really opened my eyes, because we didn't actually do what we normally do, because they're fully insured. It's a stepping stone to a little bit of data. Or actually, we will have a raw data feed. So we are going to have a lot of data, but we aren't going to be able to do much with that data under the chassis that we have them in until the following year. And we just explained this multi-year process. And they were like, oh. And you could just see the light bulb of, okay, this is how we can actually get control of this long term. So that's kind of to your point. I think we're so in it that a lot of the time we just know inherently, data is leverage, data is power. This is how you lower costs. Without that, what are we talking about? But a lot of plan sponsors and really, really intelligent executives don't realize that they even have this option. We have such a responsibility to educate. [53:24] Donovan Ryckis: All right. So what to do? I think one of the things I always talk about, if you're asking for data mid-year or after you signed a renewal and it's not within that agreement, you're probably not going to get it. So anytime you get to renewal, even if you're sticking with the incumbent carrier that you already had, you shouldn't be just negotiating that renewal on price. You should also be negotiating on terms. And the number one term you should start with is data collection, preferably a raw data feed sent to a third-party data warehouse that you own and control. [54:03] Patrick Ansara: And I think one of the things I'd point to is, you're going to get pushback when you request some of this data, and expect that. But that's when the job actually starts. And that's how we view it too, is when the carrier or vendor tells us no, that's when we start to get to work. And I think as a plan sponsor, I would just say, hey, this is our data, give it to us. And if they're not willing to do so, then you know that that vendor is on the list to be marketed for the next year. [54:33] Chelsea Ryckis: This coincides perfectly with compliance that's coming up really quickly on December 31st, 2026, known as the gag clause attestation. So if you have gag clauses in your contracts, which is exactly this, restrictions to these types of details, that's a problem. Let CMS know about it. [54:53] Donovan Ryckis: And I'd like to put this out, because anytime we tell people this, they're kind of blown away, even people within our industry. You can get raw data feeds on level-funded plans, and we've just negotiated one on a fully funded plan. So we're getting to the claim, to the penny accounting on a fully funded plan, or a level-funded kind of ASO plan, where typically that stuff isn't in there. So it's not just price when we're going to market, it's also terms. [55:21] Chelsea Ryckis: I think it goes without saying, number one is dirty across the board. I don't think that there's a lot of instances where this would be dumb. Would you guys agree? [55:30] Donovan Ryckis: Yes. Any obstruction to your own company's healthcare data, your own company spend, your own employees that are your risk and your responsibility, and you're providing a health and welfare plan for them. Any restriction there, dirty. [55:45] Patrick Ansara: Yeah, I mean, you're paying hundreds of thousands, millions of dollars on these claims that are coming through, and to not get an itemized review of all of that really makes no sense. You'd never purchase anything else in that fashion. So why do that with health? [56:00] Donovan Ryckis: Yeah, you wouldn't even go to the restaurant like that. You spent $150 on food. Imagine getting a bill. Like, what is this? Let me see. I want to see what I bought. [56:14] Chelsea Ryckis: Well, this was really fun. So this was part two of the Dirty Dozen health and welfare tips. Oh my gosh. Tricks. Tactics, whatever it is you want to call it. Basically, get your data, I think, is a big takeaway from all this. Get your data, work with aligned partners, understand that you have way more power and leverage and control than you know. And that's directed to plan sponsors. Any closing thoughts, folks? [56:38] Donovan Ryckis: I'd say, with all of these, I think the plan sponsor has ultimate control and leverage by understanding these points and negotiating them. Not the broker consultant, not the insurance company. HR, CFO, CEO, you guys can make the difference in your own health plan. [57:01] Patrick Ansara: Yeah, I couldn't agree more. I think ultimately you can't always rely on your consultant or broker to bring you all of this as options or things to introduce into your health plan. So it really does fall on the plan sponsor, but just making sure that you're aligned with whatever person you're working with, and that you're aligned with somebody who understands all of these different key elements inside of these contracts.