Case studies
Your health plan is public. Have you read it?
Every company with 100 or more people on its health plan files a public report with the Department of Labor. Here is what 52 Texas contractors’ filings show, and six companies read closely.
Every company with 100 or more people on its health plan files a report with the U.S. Department of Labor each year. It names the carrier, counts the people covered, states the premium, and lists every broker and agent the carrier paid, in dollars, with the carrier’s own description of why. Anyone can read it, it goes back years, and your competitors’ filings are in the same database as yours.
I pulled the filings for 52 Texas electrical, plumbing and HVAC contractors with 75 to 300 employees. Together they insure about 8,100 employees, pay about $55 million a year in medical premium, and paid their brokers about $2.9 million on those contracts in the latest year, about $9.5 million over six years. For companies in the same trades, the same size band and the same state, the cost per employee runs from about $2,700 to about $21,000. Broker pay runs from nothing to 14 cents of every premium dollar. Twenty of the 52 plans cover fewer people than the company employs.
Same trade, size and state: broker pay runs from 0 to 14 cents per premium dollar
Why this is the CFO’s problem
For most companies this size it is one of the largest checks they write, and nobody has priced it in years. Among the 22 companies with filings back to 2019, premium is up 30% and broker pay is up 25% at the median. Nine of the 52 have had the same carrier on the same contract number for six years. A renewal is not a market check; it is the incumbent’s opinion of what you will accept.
You are probably the fiduciary. Whoever signs the Form 5500 is the plan administrator, and ERISA holds plan fiduciaries to a duty of prudence that includes knowing what the plan pays and to whom. Since the end of 2021 the Consolidated Appropriations Act has required brokers to give the plan their compensation in writing before the contract is signed or renewed. Employees have begun suing their own employers’ plan fiduciaries over health plan costs (Johnson & Johnson and Wells Fargo were the first large cases, in 2024). The early suits have mostly been dismissed on standing, and more keep being filed. Whatever the outcome of those cases, the best protection is a file that shows the decision was made with the numbers in hand.
It is already public. Every broker in Texas can read what your current one is paid. So can a recruiter, a competitor pricing a bid against you, and the employee who wonders why their contribution went up. The only person who usually has not read the filing is the one whose name is on it.
The six studies below are drawn from that set of 52 and read from nothing but the public record. Each one shows the numbers, says plainly what they cannot establish, and ends with the three questions a CFO could put to the broker tomorrow. None of them tells you what to do. They show you what is visible, which is the part nobody has been showing you.
What the filings showed
Real companies from the public filings. Figures rounded and details removed so they can’t be traced. Exact rows on request.
| Study | Company | What the record shows | Where the pattern is |
|---|---|---|---|
| 1 · Growth and family mix | Building-trades contractor, about 160 employees | Cost per employee among the ten highest of 52 peers, but ordinary per covered person: 1.8 lives per employee and about 60% growth in two years | Coverage mix, not price |
| 2 · Flat population, rising price | Building-trades contractor, about 190 employees | Price per covered person up 27% in three years on a flat population; one carrier six years; two brokers, same pay | Rate action on a plan never re-marketed |
| 3 · Fewer covered than employed | Building-trades contractor, about 160 employees | Fewer people covered than employed, every year since 2019; three carrier changes; broker pay 6.8% with named extras | Enrollment |
| 4 · Carrier change, 24% increase | Building-trades contractor, about 150 employees | +24.5% per covered person in one year, in the year of a carrier change; above the median on cost and broker pay | The move that didn’t hold the rate |
| 5 · How the broker got paid changed | Building-trades contractor, about 130 employees | Broker pay from about $6,000 to about $45,000, mostly overrides and bonuses, across two carrier moves | How the broker is paid |
| 6 · A normal plan for half the people | Building-trades contractor, about 190 employees | “Cheapest” per employee because about 80 people are covered on a plan with about 190 employees; a filing calendar that slipped | Participation and compliance |
What the filings can tell you
- What the plan costs, per employee and per covered person, year by year. Premium per employee is the number people quote; premium per covered life is the one that tells you whether the price moved or the population did. Studies 1 and 2 are the same chart read two ways.
- How many people are actually covered. The Schedule A counts persons covered at year end. Set against the employee count on the Form 5500, it shows participation, and it showed two plans covering fewer people than work there (Studies 3 and 6).
- Who the carrier is and how long it has been there. Contract numbers carry over year to year. Six years on one contract number means the plan has been renewed, not marketed (Study 2).
- What the broker was paid, in dollars, with the carrier’s description of why. Commission is one line; “special programs,” “override,” “bonus,” “non-monetary compensation” and “general agent payments” are others, and they appear on four of the six (Studies 3 and 5 especially).
- Whether the filings were on time. The DOL records the date received. Several years filed in one batch is a compliance fact, not a plan fact, but it says something about who is minding the file (Study 6).
What the filings cannot tell you
Claims. Not one medical contract in the filings behind these studies reports claims paid or the carrier’s retention, because fully insured carriers rarely fill in that part of the Schedule A. The filings also do not show the renewal letter, the rate action in it, what the other carriers quoted, employee contributions by tier, or what the broker does for the pay. Every study ends by saying so. The number is public; the service behind it is not, and a broker who delivers claims reporting, a tested renewal and written disclosure may be worth every dollar in these tables. The question each study raises is not whether the number is allowed. It is whether anyone chose it, and where that is written down.
Want yours read?
Send me the company name. I will pull the public filings and send back the same one-page read on your plan, with your name on it instead of a number: the year-by-year table, the three facts, what the record cannot show, and the three questions for your broker. It is built from public data only, so there is nothing to sign, nothing to send me, and no fee. It is not an analysis of your plan, and it uses none of your documents.
If the questions turn up something worth a closer look, the next step is a Renewal Snapshot, $0. Nothing paid, and nothing using your documents or claims, starts before the engagement letter and broker-of-record letter are signed. Anything paid is priced in writing, in dollars and per employee, before you sign.
If you know a CFO who should see their own, forward this.
Read your own filing
The filings are public. To read your own plan, search the company name or EIN in the DOL’s EFAST2 Filing Search (efast.dol.gov/5500Search), open the latest filing and its Schedule A, and compare a few years side by side. Under the Consolidated Appropriations Act, the plan is entitled to the broker’s compensation disclosure in writing. If it is not in the file, that is the first thing to ask for.
How the 52 were chosen. U.S. Department of Labor Form 5500 and Schedule A public datasets, plan years 2019 through 2024. Texas electrical, plumbing, HVAC and other building-systems contractors with 75 to 300 participants on a fully insured medical contract, collectively bargained plans excluded. Medians use each company’s latest filing, one value per company. Short plan years are annualized, and contracts that bundle dental or vision with medical are not compared per person to medical-only plans.
Real companies from the public filings. Figures rounded and details removed so they can’t be traced. Exact rows on request. If you are a CFO, an owner’s counsel or an advisor with a reason to check a figure, ask.
Advisory analysis, not legal or tax advice.
Want your own plan read?
Send the company name to aloha@mattragudo.com. I pull the public filings and send back the same one-page read on your plan. It’s $0 and built from the public record only, so there’s nothing to sign.
Questions first? Email aloha@mattragudo.com or book a 30 minute call.