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.

If your team lacks the time, market data, or documentation practices to run a structured evaluation, outsourcing to an independent third party is usually the more defensible path. An outside evaluator brings current market benchmarks, removes internal politics from the comparison, and produces a complete decision record — typically while consuming far less executive time than an internal effort.

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. An independent evaluator with no financial ties to any bidder removes that question entirely.

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. A documented broker evaluation is how sponsors get ahead of it.

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 — a plan merger, a service issue, provider consolidation, or a material fee change. Regular, documented review is itself evidence of ongoing fiduciary oversight.

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 tell clients which level their situation calls for before any engagement begins.

Most full RFP evaluations are started and completed within 90 days, with exceptions in both directions depending on the provider category and complexity. Fee and service benchmarking typically takes about a month, and an RFI roughly 60 days. We confirm the timeline during scoping, before the engagement begins

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 revi

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.

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.