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Conflict of Interest Analysis Engine

Expose hidden financial relationships that undermine fiduciary duty

Deep Discovery

Map ownership, affiliates, and payment flows between all vendors

ERISA Protection

Document conflicts before they become DOL violations or lawsuits

Board Confidence

Give directors fiduciary assurance that vendor selections are clean

The Hidden Revenue Web

Your broker recommends a PBM. The PBM owns the specialty pharmacy. The specialty pharmacy contracts with the home infusion company your broker also recommended. The broker gets override commissions from all three. Nobody disclosed the connections. This is a fiduciary breach—and it's epidemic. Our engine maps these webs automatically from public records, ownership filings, and contract analysis.

Common Conflict Patterns

Broker-Vendor Ties
  • • Broker owns equity in PBM or TPA
  • • Override commissions from preferred vendors
  • • Revenue-sharing on specialty pharmacy
  • • Referral fees for stop-loss placement
Vendor-Vendor Ties
  • • PBM owns specialty pharmacy + mail order
  • • TPA owns disease management vendor
  • • Lab company owns wellness vendor
  • • Data warehouse owned by PBM parent
Cross-Subsidies
  • • "Free" services subsidized by hidden spreads
  • • Rebate retention offsetting admin fee discounts
  • • Specialty Rx margins funding broker bonuses
  • • Data monetization (selling plan info to pharma)
Consulting Conflicts
  • • Consultant earns fees from vendors they recommend
  • • "Independent" auditor co-owned by PBM
  • • Actuarial firm with vendor equity stakes
  • • Legal counsel representing both sides

Real-World Discoveries

Fortune 500 Retailer

$18M Hidden Revenue

Broker recommended specific PBM and specialty pharmacy. Conflict scan revealed broker's parent company owned 22% of the PBM and received 40% revenue share on specialty. Total undisclosed annual payments: $18M. Broker relationship terminated, new RFP conducted, saved $12M annually with transparent vendor.

Legal Outcome: DOL filed prohibited transaction case, broker paid $4.2M settlement for undisclosed compensation

Healthcare System (Self-Funded)

Circular Vendor Stack

TPA, PBM, and specialty pharmacy all recommended by the same consultant. Conflict analysis revealed all three vendors were subsidiaries of the same private equity firm—and the consultant's firm received equity warrants in the PE fund. Complete capture of the decision process.

Board Action: Unwound all contracts, conducted independent RFP, terminated consultant relationship, filed ethics complaint with state insurance department