Employers May Be Asking the Wrong Questions About Their Health Plans, New Survey Finds

The 2026 Phia Group Broker Survey of 124 brokers and advisors finds a disconnect between employer health plan questions and broker concerns about fiduciary processes, plan-performance visibility and vendor oversight.

Canton, MA, September 17, 2026 – Employers are entering the next health plan renewal cycle focused on familiar concerns: rising costs, pharmacy spending and plan design. But a new survey of 124 health benefits brokers and advisors suggests some of the most important questions may not be getting asked.

The 2026 Phia Group Broker Survey Results & Analysis found a disconnect between the issues employers are raising with their advisors and the risks brokers believe deserve greater attention. Brokers 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 healthcare costs are rising. Everyone is aware of that,” said Adam V. Russo, Esq., Co-Founder and CEO of The Phia Group. “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

• Only 12% of brokers are very confident that their clients have the right fiduciary processes in place, yet just 22% say fiduciary oversight is among clients' leading questions.
• 78% of brokers have no working visibility into their clients' No Surprises Act/Independent Dispute Resolution (NSA/IDR) performance.
• 62% say client visibility into subrogation and recovery is limited or very little; only 4% report strong visibility.
• Over three-fourths (76%) report that their book of business has shifted toward self-funding over the past 12 months.
• 70% report that most of their clients are seeing or expecting double-digit 2026 renewal increases.

The Broker-Employer Disconnect

Brokers see fiduciary preparedness as a primary issue, but employers aren't necessarily asking about it. More than half of brokers (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. Rather, they point to a disconnect between broker concern and client attention: Brokers 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.

Employers Can't Manage What They Can't See

The survey found significant visibility gaps in areas that can directly affect health plan performance. Seventy-eight percent of brokers report having no working visibility into NSA/IDR performance, while 44% say they don't know their clients' key NSA/IDR statistics.

Subrogation and recovery show a similar pattern: 62% describe client visibility as limited or very little, while only 4% report strong visibility into recovery opportunities, outcomes and dollars retained.

“If you don't have visibility into a part of the plan, you can't really evaluate whether it's working,” Russo said. “Employers should be asking their vendors and service providers not only what they are doing, but what results they are producing and what data the employer can actually see.”

Health Plan Management Is Becoming More Complex

Cost pressure remains significant, with 70% of brokers reporting that most of their clients are seeing or expecting double-digit 2026 renewal increases. At the same time, 76% report that their book of business has shifted toward self-funding over the past 12 months.

The shift toward self-funding may give employers greater control over plan financing, but it also increases the importance of understanding plan performance, overseeing vendors and documenting decisions.

Pharmacy is emerging as more than a cost problem. It is becoming a transparency and management issue, too. Twenty-seven percent of brokers say PBM transparency and rebate questions are among the leading questions they receive from clients. Meanwhile, 18% identify pharmacy and specialty drug costs as their biggest pressure point, and 16% say pharmacy, PBM and specialty drug costs are among the issues the industry is underestimating the most. The findings suggest employers are increasingly looking beyond the price of prescription drugs to understand how pharmacy spending is structured and managed.

The Broker's Role Is Changing

The survey also points to a growing demand for practical tools to help brokers 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 healthcare 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.”

The 2026 Phia Group Broker Survey Results & Analysis further examines the issues shaping employer health plans, including cost pressure, self-funding, pharmacy spending, fiduciary responsibility, NSA/IDR and recovery visibility, broker resources and AI adoption. The survey also finds that 44% of brokers regularly use AI in their work, while another 26% use it occasionally.

For brokers and advisors interested in more information about The Phia Group, please contact partnerships@phiagroup.com.

Survey Methodology

The 2026 Phia Group Broker Survey received 124 submissions. Questions allowing multiple selections may total more than 100%, and open-ended responses were coded to one primary theme.

About The Phia Group

The Phia Group empowers health benefit plans and sponsors through innovative consulting, cost containment, and plan management services. Founded in 2000, Phia reduces the cost of health benefits and improves access to quality care through innovative technologies, legal expertise, and focused, flexible customer service. By providing the industry with best practices and staying true to a forward-thinking methodology, The Phia Group boasts an all-encompassing cost containment program for the ever-changing healthcare industry. Learn more at phiagroup.com.

Media Contact

Jamie LaDuca
jamie@143pr.com
781-771-2697