For self-funded health plan sponsors, the annual gag clause attestation is more than a bureaucratic checkbox. It is a legal statement about the language in their service contracts, yet many sponsors sign without having read the relevant clauses. The Consolidated Appropriations Act of 2021 requires plans to certify that no agreement restricts the disclosure of cost and quality information or access to claims data. With the deadline approaching each December 31, the risk of non-compliance is substantial.
Enter MOC Fiduciary Intelligence, an AI-powered platform from Model Optimal Care, accessible at fiduciaryIQ.ai. The platform reads administrative services agreements, PBM contracts, stop-loss policies, network agreements, and other documents to identify restrictive language that could violate the gag clause prohibition. It then produces a comprehensive fiduciary report and score, with citations to the specific contract sections. This transforms a daunting manual review into an efficient, data-driven process.
What is MOC Fiduciary Intelligence?
MOC Fiduciary Intelligence is an artificial intelligence solution designed specifically for self-funded health plan sponsors. It leverages the Model Optimal Care framework to evaluate contracts against 32 fiduciary indicators drawn from ERISA, the CAA, and best practices. The platform does not rely on user memory or self-reporting; it reads the actual contract text. Users can ask questions in plain language and receive answers cited to the relevant page in their own documents. The result is a clear fiduciary score on a scale of 1 to 10, along with a detailed breakdown of findings.
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The platform also includes a free one-month trial that provides one comprehensive fiduciary report and score. No credit card is required to start, allowing sponsors to evaluate the tool before committing. This low barrier to entry makes it accessible for plans of all sizes.
What stands out about the platform
Key features that set MOC Fiduciary Intelligence apart include:
- AI-driven contract analysis: The platform reads service agreements and flags restrictive language that could violate the gag clause rules. It identifies clauses that limit data access, treat rates as trade secrets, or restrict disclosure.
- Comprehensive fiduciary score: Each plan receives a score from 1 to 10 based on 32 indicators, with citations to the governing provisions. This score provides a clear benchmark for fiduciary health.
- Plain language Q&A: Sponsors can ask questions in natural language and get answers directly from their contracts. This makes the findings accessible to non-legal team members.
- Free trial with no risk: The one-month free trial includes a full fiduciary report and score, with no credit card required. It is an opportunity to see the value firsthand.
- Support for multiple contract types: The platform can analyze administrative services agreements, PBM contracts, stop-loss policies, network agreements, and more.
These features collectively ensure that sponsors are not signing attestations based on assumptions. The platform provides evidence-based insights that reduce the risk of non-compliance.
Who can benefit from this tool
MOC Fiduciary Intelligence is primarily designed for self-funded health plan sponsors, which cover 67 percent of covered workers and over 160 million Americans. These sponsors bear the fiduciary duty to ensure their contracts comply with the gag clause prohibition. The platform is equally valuable for third-party administrators who file attestations on behalf of plans, as it helps them verify the underlying contracts.
Fiduciaries, benefits consultants, and legal advisors can also use the platform to audit plans and identify savings opportunities. The tool’s ability to flag wasteful spending—in one sample review, it identified $5.23 million in potential savings—makes it relevant beyond compliance alone. Any organization involved in managing self-funded health plans will find the platform useful.
What makes it worth considering
The annual attestation deadline creates a recurring compliance obligation that many sponsors struggle to meet. MOC Fiduciary Intelligence addresses this pain point by automating the most time-consuming part: reading and interpreting contracts. The platform not only identifies restrictive language but also provides a clear action plan for remediation.
Beyond compliance, the platform offers fiduciary intelligence that can improve plan performance. By analyzing contracts for waste and inefficiency, it helps sponsors optimize spending. The free trial allows prospective users to experience these benefits without any financial commitment, making it a low-risk investment in fiduciary integrity.
Verdict
MOC Fiduciary Intelligence is a powerful tool for any self-funded health plan sponsor serious about fulfilling their fiduciary duties. It simplifies a complex legal requirement, provides actionable insights, and helps prevent costly mistakes. The free trial makes it easy to get started, and the platform’s AI-driven approach ensures accuracy and efficiency.
For plan sponsors who want to move beyond guesswork and ensure compliance with confidence, MOC Fiduciary Intelligence is an indispensable resource. Its combination of contract analysis, scoring, and plain language reporting sets a new standard for fiduciary oversight in the health plan industry.
Frequently asked questions
It is an annual filing required by the Consolidated Appropriations Act of 2021, where self-funded health plan sponsors certify that their service contracts do not restrict disclosure of cost and quality information or access to claims data.
The platform reads service contracts (ASA, PBM, stop-loss, network agreements) and flags any restrictive language that could violate the gag clause prohibition. It provides a fiduciary score and cites the specific contract sections.
It can analyze administrative services agreements, PBM contracts, stop-loss policies, network agreements, and other service provider contracts relevant to self-funded health plans.
Yes, MOC Fiduciary Intelligence offers a free one-month trial that includes one comprehensive fiduciary report and score. No credit card is required to start.
It is designed for self-funded health plan sponsors, TPAs, fiduciaries, benefits consultants, and legal advisors who need to ensure compliance with the gag clause attestation and improve fiduciary oversight.
The platform evaluates contracts against 32 fiduciary indicators drawn from the Model Optimal Care framework, ERISA, and the CAA. It returns a score from 1 to 10, with each finding cited to the governing provision.
