Most employers still approach fiduciary reform as a solo project: negotiate with the PBM, fix the contract, clean up the data.
But the real breakthrough happens when those individual actions connect. When transparency, accountability, and data all compound across organizations.
That’s the Fiduciary Network Effect: where every improvement strengthens the system for everyone else.
Executive Brief
Why the Network Matters
When fiduciaries align around common principles of transparency, accountability, and data access, the benefits multiply:
Contracts improve faster as every review strengthens a shared model.
Procurement gets smarter as RFPs reuse proven language.
Benchmarking becomes actionable when data is shared.
Transparent PBMs gain validation by proving alignment.
That’s the new market dynamic: performance verified through shared standards. It’s not anti-PBM; it’s pro-proof.
Agglomeration > incumbents. If you’re building in this space—DPC, Health Rosetta-style brokers, direct-contract networks, transparent TPAs, payment-integrity firms, aligned consultants—don’t be scared of the competition in your space, embrace it. Let’s stop trying to win as lone boutiques and start winning as a visible, interoperable agglomeration.
Chris Deacon, Healthcare Leader and Truth Teller
That’s exactly what Nautilus is doing: Creating the connective tissue that makes agglomeration real.
Chris Deacon, Healthcare Leader and Truth Teller
From Compliance to Collective Intelligence
The fiduciary network model works because it’s not proprietary.
Every organization that completes a Nautilus Contract X-Ray or adopts the model contract clauses contributes to a smarter system. Each improvement becomes a shared advantage.
Here’s how the ecosystem fits together:
Contract X-Ray → Identifies clause-level risks and missing terms.
Contract Configurator → Translates those findings into standardized RFI/RFP language.
Benchmarking Data → Aggregates anonymized insights across employers.
Validation → Gives PBMs a way to prove they meet fiduciary standards.
Each step feeds the next creating a virtuous cycle of proof, performance, and trust.
Don’t Just Say It. Prove It.
Transparency isn’t a marketing label. It’s a test.
The PBM industry has no shortage of self-declared “transparent” models. What’s missing is a standard of proof. Verifiable contract terms, full financial disclosure, and ongoing performance data.
That’s where Nautilus comes in:
Model Clauses define fiduciary-grade contract language.
Contract X-Ray verifies compliance in practice.
Benchmarking Tools quantify the gap between promise and proof.
Data Standards ensure every result improves the next review.
This isn’t about policing vendors. It’s about protecting fiduciaries and proving value in a measurable, repeatable way.
Nautilus gives the industry a way to validate what “transparent” actually means.
Case Study: The Flywheel in Motion
When one employer identifies a hidden, problematic clause, that discovery updates the model language library.
The next employer using Nautilus tools benefits automatically without even knowing who found it first.
And when a transparent PBM accepts model clauses, the standard gets stronger for everyone.
That’s the Fiduciary Flywheel:
Each review improves the repository.
Each repository update improves the next review.
Each organization accepting those standards accelerates trust for everyone.
Fiduciary Flywheel
Key Takeaways
The Fiduciary Network Effect turns individual compliance efforts into collective leverage.
Each employer, advisor, attorney, and PBM contributes to a smarter, fairer system.
Proof, not promises, is the new benchmark for transparency.
Shared intelligence is the only sustainable path to reform.
Fiduciary strength grows exponentially when we work from a common standard.
The more we share what works, the faster we fix what’s broken.
A Note of Thanks
Chris Deacon
Chris Deacon, founder of VerSan Consulting and author of The Great American Healthcare Heist, has spent over 20 years at the intersection of law and healthcare reform. A longtime advisor to Health Rosetta and a valued contributor to Nautilus, Chris continues to shape procurement standards putting fiduciary duty and participant interests first.
Visit nautilushealth.org/pbmto find educational resources, procurement tools, model contract terms, the PBM Configurator, and other tools.
💸 SPECIAL OFFER: Newsletter subscribers receive 10% off any Validation Institute service. Use code FIDUCIARY10 at checkout.
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📬 PAY IT FORWARD: Feel free to forward this offer to your broker, PBM, or other vendors. Don’t hesitate to tell them you will favor validated vendors as part of your modernized procurement processes. Strong compliance and better benefits begin with validation.
Don’t be a bystander. Change the status quo and reap the benefits of The Health Plan Compliance Advantage.
