Transparency and Fiduciary Literacy Redefine 2026 Employer Health Benefits Strategy

For many business leaders, 2026 is becoming a flashpoint for employer-sponsored health benefits. A wave of double-digit renewal increases is colliding with years of transparency failures, forcing employers to face a new reality of untenable costs and heightened legal risk. The downstream impact on employees is direct, squeezing retirement savings and eroding trust as workers face mounting pressure from out-of-pocket costs. The financial shock isn't a one-year anomaly, but the exposure of a much deeper education and governance gap within the industry.

Justin Leader is President and CEO of BenefitsDNA, where he works with employers and plan sponsors to expose hidden healthcare costs and rebuild benefits strategies around transparency, fiduciary accountability, and clean data. A long-time advocate for health insurance and PBM transparency, Leader brings experience that spans pharmaceutical sales, financial services, and benefits advisory. That background shapes his focus on education, governance, and restoring trust in employer-sponsored healthcare.

"The largest exposure an employer has is the lack of education and the lack of understanding of what's actually going on within their plan," says Leader. He sees the issue as structural, not accidental. Complexity and opacity keep plan sponsors from understanding how their plans actually function, limiting their ability to govern costs, contracts, and risk before problems surface.

• The four-part puzzle: At its core, Leader argues, a health plan isn’t inherently complex, but it is often made to appear that way. "A health plan has just four basic components: the administrator, the network, the PBM, and the insurance itself. Most plan sponsors don't understand that basic fact, let alone the contractual games played to hide and extract money from them. It's really, really dire."

The promise of transparency from the Consolidated Appropriations Act has remained largely unfulfilled, with many employers citing a lack of enforcement as the reason. That lack of enforcement has created a frustrating reality where plan sponsors often must send demand letters for data their vendors have already attested is accessible. Leader says compliance failures around requirements like gag clause attestations and RxDC reporting have become commonplace.

• Phantom transparency: "These are actions that are nothing short of consumer protection violations. Still, we have to write demand letters to access this information even when vendors have attested to the federal government that there's nothing limiting the plan sponsor from receiving this information," he says. Ultimately, Leader's point is that without price transparency, any system will struggle to remain sustainable. He believes the use of expensive subsidies treats only the symptoms, leaving the root problem of runaway costs unaddressed and untethered from the realities of a functional market.

• Band-Aids for bullet holes: He points out that many "fixes" are flawed and temporary. "With the ACA subsidies, we've applied Band-Aids for bullet holes. We have subsidized the major insurers by providing a subsidy without ever fixing the structural issues that exist, like why we pay such high costs for procedures, services, and drugs in this country."

• David vs. Goliath: The struggle has transformed the work for a growing number of advocates into what Leader calls a "moral obligation." But there are early signals of a market correction, driven by two key forces. The first is a revolution from the next generation, building technology to fix a broken paradigm. The second is the rise of grassroots action, like Pennsylvania's community-owned health plan initiative. Leader views these efforts as powerful signals of a growing movement. "There are good colleagues out there desperately fighting. We're going up against billion-dollar entities with million-dollar marketing budgets and talented sales folks," he says. "In a David versus Goliath scenario, David usually does alright in the end. You drop the pebble and it ripples over."

What comes next will not be dictated by another regulation, subsidy, or election cycle. It will be defined by whether employers are willing to step into their role as true fiduciaries, unwilling to accept "that’s just how it works" as an answer. As costs continue to rise and scrutiny intensifies, the real divide will be between employers who stay passive and those who decide the status quo is no longer acceptable.