What a $23.5m health benefits failure teaches self-funded employers
Columbus schools averted an employee surcharge crisis, but the consultant oversight gaps it uncovered apply directly to private-sector plan sponsors
What a $23.5m health benefits failure teaches self-funded employers
GROUP BENEFITS
By Mark Rosanes
29 Sep 2026

A forensic audit of Columbus City Schools found that a troubled arrangement with insurance consultancy Aon cost the Ohio district at least $23.5 million and depleted its self-insurance fund reserves. The damage was severe enough that district employees faced premium surcharges of up to 25% for 2027. A unanimous Joint Insurance Committee vote on September 28 averted that outcome, capping premium increases at 8% through plan changes negotiated with unions.

The Columbus Dispatch, which broke and tracked the story, reported that the audit concluded Aon "generally treated the district as a taxpayer-funded cash cow." Aon collected more than $300,000 in flat fees for 2024 and 2025, plus commissions the audit said the firm refused to disclose. The benefits plan Aon produced relied on cost projections the audit found were materially wrong, causing the district to overspend against its self-insurance fund.

The underlying failure is not specific to a school district. It describes what happens when a self-funded employer has no governance structure around its consultant relationship.

How the failure unfolded

The Aon arrangement carried two compounding risks. Aon collected both flat consulting fees and undisclosed commissions, giving the district no basis for evaluating whether the arrangement was reasonable. The benefits plan also rested on cost assumptions that proved materially wrong, with no independent review mechanism in place to catch the error before reserves were depleted.

CCS Superintendent Angela Chapman said the district is committed to quality health benefits and a fair cost-sharing arrangement. Columbus Education Association President John Coneglio told the Dispatch that the district had not been transparent with the union about the scale of the problem. The CEA filed a grievance in August and issued three demands: legal action against Aon, independent auditing and monitoring measures, and a structured resolution process with employees.

Those three demands map closely onto what a sound employer benefits governance program includes before a crisis develops.

What private-sector plan sponsors owe

Columbus City Schools is a public employer and sits outside the scope of the Employee Retirement Income Security Act (ERISA). Private-sector employers operating self-funded group health plans face different obligations. Under ERISA Section 408(b)(2), consultants and brokers serving private employer health plans must disclose all direct and indirect compensation, including third-party commissions, before an arrangement begins.

Congress extended that requirement to group health plan service providers through the Consolidated Appropriations Act, 2021. The scenario Columbus encountered is not unusual. A consultant receiving undisclosed commissions from vendors has a financial interest in the plan design that the employer cannot assess without knowing the commission structure.

Even with disclosure requirements in place, the duty to request, review, and act on that information falls on the plan sponsor. Benefits brokers increasingly report that clients have not done so - a 2026 survey by The Phia Group found only 12% of benefits brokers are very confident their clients have adequate fiduciary processes in place.

The Columbus case also exposes a second gap. The district's self-insurance fund was depleted by cost overruns against projections it accepted without independent scrutiny. ERISA requires private-sector plan fiduciaries to act prudently and monitor vendors, which in practice means benchmarking costs and reviewing projection assumptions.

That documented oversight process is now a factor in fiduciary litigation exposure for self-funded employers, as courts extend to health plans the same theories that drove 401(k) litigation. An emergency negotiation, a forensic audit, a union grievance, and prospective legal action against a former consultant describe what the governance failure looks like when it catches up with the plan.

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