Chris Vanderwolk, Esq. CEBS
Chris Vanderwolk is an ERISA attorney, a writer on employee benefits compliance, and a national leader within the National Association of Benefits and Insurance Professionals. He is the Director of Compliance and Innovation for OneDigital | Kistler Tiffany Benefits General Agency.
Writing
Follow Vanderwolk.esq on Substack for plain-language explanations of complicated benefits compliance issues like fiduciary duty, debunking double-dipping, and other hot topics.
Pro Bono Practice
Vanderwolk Law LLC operates a pro bono legal practice serving United States military veterans through Volunteer Lawyers for Justice. This is the firm’s current active engagement.
Focus Areas
✓ ERISA Fiduciary Duty
✓ PBM Contracting and Oversight
✓ MHPAEA and NQTL Compliance
Experience
Two decades in employee benefits. JD and CEBS. Admitted in New Jersey.
Grounded in operating experience: third-party administration, employer compliance, and the day-to-day mechanics of self-funded health plans, and the legal framework that governs them.
19+
Years in Employee Benefits
Across third-party administration, brokerage and consulting, employer compliance, and fiduciary practice.
8
Credentials
JD, CEBS, GBA, CMS, CFC, GBDS, Life and Health License. License to Practice Law in New Jersey
400+
Published Posts
On ERISA fiduciary duty, PBM oversight, and federal benefits compliance, across LinkedIn and Substack.
Areas of Focus
Where fiduciary duty meets practical operations.
The questions most plan sponsors face — how to evaluate a PBM contract, whether their stop-loss structure is defensible, what their named fiduciary actually owes — sit at the intersection of legal obligation and operational reality. The writing here focuses on that intersection.
Current FOcus
CAA 2026 and the new PBM audit framework.
The Consolidated Appropriations Act of 2026, signed in February, established the first federal framework requiring pharmacy benefit managers to disclose rebates, fees, and pricing to plan fiduciaries on demand — and to permit annual audits chosen by the plan, not by the PBM. This is the most significant change to health plan oversight in a decade. Much of the current writing is focused here.
“Move fast and break things doesn’t work when what it breaks is the law or access to care.”
Speaking Topics
ERISA Fiduciary Duty for Self-Funded Health Plans
What the duty actually requires, who holds it, and what happens when it is not met. Built for plan committees, brokers, and the executives who sign plan documents.
MHPAEA and NQTL Compliance
Where the Non-Quantitative Treatment Limitation analysis actually breaks down for self-funded plans, and what enforcement under the 2024 final rule looks like.
The PBM Audit Framework Under CAA 2026
What the new audit rights mean in practice, how to choose an auditor the PBM does not control, and what employers should expect to find when they look.
The Named Fiduciary Under ERISA 402(a)
Why the named fiduciary role has been the quiet center of recent class-action litigation, and what plan sponsors and brokers should understand about who is actually exposed.
Speaking Inquiries
For keynotes, podcast appearances, panel discussions, and continuing education programs on ERISA, PBM contracting, and health plan fiduciary topics.
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Benefits Brief · Health & Welfare Edition · July 3, 2026
Compliance Calendar — upcoming deadlines Jul 31 PCORI fee due (Form 720) for self-insured health plans Jul 31 Form 5500 due for calendar-year plans (without extension) Dec 31… Continue Reading
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When to consider paying cash instead of using insurance (and which tools to use to figure that out).
Start the new year by exploring tools to compare healthcare costs. First, check your insurance carrier or TPA’s site, as costs outside negotiated rates might not count toward… Continue Reading
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What’s driving U.S. drug prices so high?
A new analysis by Petersen-KFF raises a critical question: Are countries like Germany, the U.K., and Australia paying less because they’ve negotiated better deals, or is it the… Continue Reading
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We were so close.
To say I’m disappointed today is an understatement. We were so close. So close to finally making progress as a nation to control our out-of-control drug costs. But… Continue Reading
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Yes, Virginia, there is a Santa Claus. 🎅🏽
Congress is including some real PBM reform in the 1,547 page Continuing Resolution that must pass this week to keep the government running. Here’s some of the employer… Continue Reading
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What’s up(coding)?
What’s up(coding)? Let’s talk about a common practice that needs to end. After you leave the doctor’s office, what happens to your chart? It goes to a billing… Continue Reading
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RxDC insights on Rebates and “Gross to net”
The U.S. Department of Health and Human Services (HHS) analyzed two years of RxDC reporting and revealed key findings on prescription drug costs: • 46% of tracked drugs… Continue Reading
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Let’s talk about the Employer Tax Exclusion
The Employer Tax Exclusion emerged during WWII, when a federal wage freeze prompted employers to offer health benefits as tax-exempt compensation. Today, that system covers 164 million Americans.… Continue Reading
Personal site of Christopher Vanderwolk. Vanderwolk Law LLC is a New Jersey limited liability company. Nothing on this site is legal advice. Views are the author’s own and do not represent the views of any employer. No attorney-client relationship is created by visiting this site or by any communication that does not include a signed engagement letter.
© 2026 Christopher Vanderwolk. All rights reserved.
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