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Many of the actions taken by an employer providing health insurance under a plan whereby a portion is contributed by the employee will make the employer a "fiduciary" to that employee. That is a position created by the nature of the actions as opposed to only being created by some type of "paperwork".
You do need a "plan" which includes documents which contain a description of the plan as well as various other items. Most small employers find it is a better idea to hire a third party administrator to handle this rather than doing it themselves since any mistakes can have serious repercussions from the government or from the employees.
The Department of Labor has a very detailed web page that explains all of these issues at https://www.dol.gov/ebsa/publications/ghpfiduciaryresponsibilities.html
It is pretty lengthy but it is comprehensive and reading through it will quickly give you an idea of why most small businesses hire a third party administrator.
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