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What Legal Needs to Know About Self-Funding But Might Not Ask

In this episode of Blueprints for Better Benefits, Rodney Mattos Jr. and Rodney Mattos Sr. unpack what legal teams need to know about self-funding, especially the responsibilities many employers misunderstand or address too late.

From ERISA fiduciary duties and plan documents to HIPAA oversight, vendor contracts, and non-discrimination testing, this episode explains what legal teams, HR leaders, CFOs, and decision-makers need to know to reduce risk and build a plan that holds up when it matters most.

Topics We Cover

  • Why the employer remains the plan sponsor and fiduciary in both fully insured and self-funded plans
  • What legal teams should review before a self-funded plan is implemented
  • Why generic or outdated plan documents can create avoidable exposure
  • How appeals processes, discretionary authority, and employer override clauses work
  • What to look for in TPA, PBM, stop-loss, and vendor contracts
  • How HIPAA compliance and business associate agreements should be managed
  • Why Section 105(h) non-discrimination testing matters
  • How captive governance and fiduciary liability coverage help protect employers

Key Takeaway

Self-funding is not just a financial strategy. It is also a legal, fiduciary, and governance decision. When the right structure is put in place from the beginning, employers gain more clarity, more control, and a stronger foundation for protecting both the plan and the people it serves.

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Connect with Rodney

Email: rmattos@triforta.com

LinkedIn: https://www.linkedin.com/in/rodneymattos/

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