Scoring methodology · v1.0
The whole rubric, in public.
A score you cannot audit is an opinion. This page is the complete method: the arithmetic, what each band obliges you to do, the 7 controls that fail an assessment outright, what this does not cover, and how a provider disputes a result. No part of the score is produced by a language model.
- Domains
- 12
- Questions
- 64
- Weight units
- 20
- Automatic fails
- 7
How the score is computed
How the score is calculated
Each domain is scored independently: answered questions earn 1 point for Yes, 0 for No. N/A answers are excluded from the denominator — they don’t penalise providers for genuinely inapplicable controls.
Domain score = Yes answers ÷ Applicable questions × 100
Overall score = Σ (domain score × weight) ÷ 20
8
High-weight domains
Count 2×
4
Medium-weight domains
Count 1×
20
Total weight units
Denominator
High-weight domains cover controls where failures directly expose participant funds or PII — Access Controls, Encryption, and Business Resiliency among them. 7 specific failures (like no MFA, no encryption, or an unassessed sub-processor) are automatic red flags — see the risk bands to the right for what a red flag does to the final score.
Risk rating bands
The overall score maps to one of four risk bands. Band thresholds are fixed and auditable — no LLM adjusts them at runtime.
Strong
90–100%
Adequate
75–89%
Needs Improvement
60–74%
High Risk
0–59%
Any single red flag — an automatic-fail control, such as no MFA or unencrypted data — forces the band straight to High Risk, regardless of the numeric score. Red flags are disclosed explicitly in the report so fiduciaries can act on them.
You can’t N/A your way out of a domain
Because N/A answers leave the denominator, marking an entire domain N/A would quietly remove it from the score. Exactly one domain may be excluded that way — Domain 8, the software-development lifecycle, since most plan and fund offices don’t build software. Every other domain must be genuinely answered: a submission that blanks one out is rejected rather than scored, so a weak area can’t be hidden by omission.
What the AI does — and never does
The score above is computed entirely in deterministic code. The AI layer does one thing: it reads the free-text comment behind each “Yes” and grades how well that comment substantiates the claim — a named tool, document, or date scores high; boilerplate scores low; answering Yes with no evidence at all never earns full credit. That produces a second, clearly-labelled evidence-adjusted score shown beside the official one.
It never sets a Yes or No, never moves the official score, and never cancels a red flag. If the AI is unavailable, the assessment still scores normally.
What each band means, and what to do
A band is not a grade for its own sake. Each one carries a prescribed course of action, so the result can go into a board minute with the decision it implies already attached.
No material shortfall against the DOL's twelve best practices, and no automatic-fail control missed.
Do this: Retain and re-assess annually. Keep the result in the file as evidence of a prudent selection and monitoring process.
Controls are broadly in place with noteworthy shortfalls in one or more domains — none of them automatic fails.
Do this: Retain, but put the specific gaps in writing to the provider with a remediation date, and re-check at the next cycle.
Shortfalls are significant and concentrated enough that a reasonable fiduciary would not treat this as settled.
Do this: Require a written remediation plan with dates before the next contract renewal. Document the request and the response.
Either the weighted score is below 60, or an automatic-fail control was missed. A single automatic fail lands here regardless of the numeric score.
Do this: Escalate now. Obtain written remediation commitments, consider whether the relationship can continue, and record the decision and its basis.
The 7 controls that fail an assessment outright
Missing any one of these sets the rating to High Risk regardless of the numeric score. They are listed here in full so a provider can check them before submitting, and so a sponsor can see that the escalation is rule-based rather than discretionary.
- 1No SOC 2 Type II report or equivalent independent third-party audit (Domain 3).
- 2Multi-factor authentication not enforced for remote or administrative access (Domain 5).
- 3Participant data not encrypted at rest or in transit (Domain 10).
- 4Vendor can move plan assets or process distributions without documented controls (Tiering Q5–Q6 with Domain 5).
- 5An undisclosed, or unremediated, past incident (Domain 12).
- 6No documented incident-response plan (Domain 9).
- 7Sub-processors with access to plan data that are not security-assessed (Domain 6).
What this method does not do
Stated plainly, because a rubric that claims no limits is not credible.
- This is a self-assessment. Answers are supplied by the service provider; Paladin scores them, it does not independently verify each one. The evidence-quality layer grades how well a written answer substantiates itself, but it cannot confirm a control exists.
- A score reflects what was true on the submission date. Controls drift; a result more than twelve months old should be treated as stale.
- Twelve DOL EBSA domains are not the whole of information security. A Strong rating means no material shortfall against this framework, not that the provider cannot be breached.
- N/A answers are excluded from a domain's denominator. Exactly one domain (software development lifecycle) may be excluded wholesale, and N/A is rejected on automatic-fail controls unless the scoping answers establish it is genuinely inapplicable.
- The score is not legal advice and does not by itself discharge a fiduciary duty. It is evidence of a documented, repeatable process.
Disputing a result
A provider who believes an answer was recorded incorrectly can contest it. Target response: 5 business days.
- 1.The provider, or the plan sponsor on their behalf, submits the question number in dispute and the evidence they say contradicts the recorded answer.
- 2.Paladin re-runs the deterministic engine against the corrected answer set. Because the rubric is published and the arithmetic is fixed, the effect of a correction is predictable before it is applied.
- 3.If the correction is accepted, the assessment is re-scored and the revised result supersedes the original. Both versions are retained — the original is not deleted, because the sponsor's file needs the history.
- 4.If it is declined, the reason is given in writing against the specific rubric line relied on.
Disputes: methodology@paladinassurance.com
Version history
v1.0 — current. Twelve domains, 64 questions, 8 high-weight and 4 medium-weight domains, 7automatic-fail controls. A change to the rubric changes this version, and any assessment records the version it was scored under — so two results are always comparable or explicitly not.
Run an assessment against this rubric