One of the hardest parts of being a plan provider isn’t the complexity of ERISA—it’s the incomplete information. Providers are often asked to solve problems without being given the full picture, and that’s a recipe for compliance failures that no service agreement disclaimer can truly fix.
Plan providers rely on plan sponsor data to perform testing, draft amendments, determine eligibility, and spot compliance risks. Controlled group ownership, affiliated service groups, other retirement plans, payroll practices, mergers, acquisitions—none of this is optional context. When sponsors leave out details, whether intentionally or accidentally, providers are forced to work with blind spots that can undermine even the best systems and expertise.
The frustrating reality is that when issues surface years later, providers are often pulled into the blame cycle despite never having the facts needed to prevent the problem. The IRS and DOL don’t audit based on what the provider was told; they audit based on what actually happened. That disconnect creates unnecessary exposure for everyone involved.
Providers need to be proactive in setting expectations. Data-collection processes should emphasize completeness, not convenience. Annual questionnaires shouldn’t feel like busywork; they should be framed as risk-management tools that protect the sponsor and the provider alike. Educating sponsors on why certain questions matter can reduce resistance and improve accuracy.
Plan providers aren’t miracle workers. They can’t fix problems they don’t know exist. The best provider-client relationships are built on transparency, not assumptions. When providers insist on better information up front, they’re not being difficult—they’re doing their job.
