As employers enter the next health plan renewal cycle, they might not be as prepared as they think. According to a new survey of 124 health benefits brokers and advisors, some of the most important questions they should be asking could go unasked.
The 2026 Phia Group Broker Survey Results & Analysis found a disconnect between the issues employers are raising with their advisors and the risks advisors believe deserve greater attention. Advisors report significant concerns about fiduciary preparedness and visibility into health plan performance as it relates to No Surprises Act (NSA), Independent Dispute Resolution (IDR), and subrogation and recovery.
As employers increasingly move toward self-funded plans and face more complex decisions around pharmacy, claims, vendors, and fiduciary oversight, brokers say the traditional renewal conversation is no longer enough.
“The biggest finding isn’t that health care costs are rising. Everyone is aware of that,” said Adam V. Russo, Esq., co-founder and CEO of The Phia Group, a health care cost-containment and compliance company. “It’s that employers are being asked to make increasingly sophisticated decisions about their health plans, while brokers are telling us there are still fundamental gaps in visibility and governance. The question is no longer just whether an employer can afford its health plan. It’s whether it can understand, oversee, and defend the decisions it is making.”
Survey key findings
Russo said the company’s conclusions are based on some of the survey’s key findings, which include the following:
- Only 12% of advisors are very confident that their clients have the right fiduciary processes in place, yet just 22% say fiduciary oversight is among clients’ leading questions.
- Nearly 80% of advisors have no working visibility into their clients’ No Surprises Act/Independent Dispute Resolution (NSA/IDR) performance.
- Roughly two-thirds (62%) said client visibility into subrogation and recovery is limited or very little; only 4% report strong visibility.
- More than three-fourths (76%) reported that their book of business has shifted toward self-funding over the past 12 months.
- Almost three-fourths (70%) reported that most of their clients are seeing or expecting double-digit 2026 renewal increases.
Advisors see fiduciary preparedness as a primary issue, but employers aren’t necessarily asking about it. More than half of advisors (54%) say a fiduciary oversight checklist would help them advise clients more effectively.
The findings do not establish that employers are failing to meet their fiduciary obligations, according to The Phia Group. Rather, they point to a disconnect between advisor concern and client attention: Advisors are identifying fiduciary processes, documentation, and plan oversight as areas requiring attention, while those issues are not necessarily making it onto the employer’s agenda.
The survey also points to a growing demand for practical tools to help advisors navigate increasingly complex health plan matters, including fiduciary oversight checklists, claims and cost-driver analysis, transparent vendor and TPA reporting, benchmark data, and client-ready education materials.
“The broker’s role is changing,” Russo said. “It’s not enough to tell a client that health care costs are increasing. The more valuable conversation is helping the client understand what is driving those costs, what the plan can see, which vendors are performing, what decisions need to be documented, and where there may be opportunities to improve performance.”