In today’s benefits ecosystem, data is the new currency. Claims data, eligibility files, engagement metrics, clinical insights, and behavioral signals fuel AI tools that promise efficiency, personalization, and cost optimization.
Here’s the problem: most employers don’t actually know where their data is going, or how it’s being used once it gets there. That blind spot is becoming a bigger risk.
AI isn’t the risk, unaccounted for data is. Unprotected data risks noncompliance with HIPAA and privacy rules, areas with increasing legal scrutiny.
Artificial intelligence is no longer theoretical in healthcare. It’s embedded—quietly and pervasively—across the benefits value chain.
- Vendors are using historical claims data to predict future risk and utilization
- Navigation tools are analyzing behavior patterns to influence care decisions
In fact, 60% of adults are now using AI to navigate healthcare. Many of these applications depends on employer-owned data, yet the governance of that data often sits outside the employer’s direct line of sight.
Forward-thinking employers are beginning to flip the script by treating their data as a strategic tool, not a byproduct.
Benefits navigation with guardrails
One organization deployed conversational AI to answer employee benefit questions—but only after establishing strict data-use boundaries. The AI could explain coverage and guide next steps, but it could not store, reuse, or repurpose employee health information outside of the employer’s defined governance rules.
Vendor accountability through data transparency
A client we advised discovered that multiple vendors were independently ingesting the same data sets, each applying different algorithms and assumptions. By reclaiming ownership and standardizing data access, the employer reduced redundancy, improved reporting accuracy, and strengthened fiduciary oversight.
The common thread?
Intentional data ownership.
As AI becomes more deeply embedded in benefits administration, passive governance is no longer sufficient. This is where fiduciary scans are emerging as an essential risk‑management tool.
Think of a fiduciary scan as a stress test for your data ecosystem, designed to surface vulnerabilities before they become liabilities. A scan examines:
- Where plan data flows
- Who can access it
- How it can be reused
- What documentation supports fiduciary decisions
- Where human oversight is required
With one client, a fiduciary scan revealed five key documentation gaps that increased exposure. Once identified, processes were codified, vendor expectations clarified, and controls put in place—without disrupting operations.
The Bottom Line: Ownership Is the Strategy
As a plan sponsor, you are not just purchasing benefits. You are accountable for the steps you take to ensure your employee data is not misused, even by third parties.
AI should be utilized to enhance decision‑making without replacing human judgment and to align innovation with fiduciary duty.
AI can amplify value, but only if employers set the rules.
Ask yourself:
Do you know exactly who is using your data, how it’s being used, and where fiduciary responsibility sits?
If not, the risk isn’t hypothetical anymore.
