Broker Compensation Transparency Requirements

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Signed into law in late 2020, the Consolidated Appropriations Act, 2021 (CAA) created new requirements for health insurance brokers and consultants to disclose any direct or indirect compensation they may receive for referral of services to ERISA-covered group health plan sponsors. Similar disclosure to enrollees in the individual market or enrollees purchasing short-term limited duration insurance is required for referral of coverage.

These new disclosure requirements began on Dec. 27, 2021, although the U.S. Department of Labor (DOL) has announced a temporary enforcement policy. According to the DOL, a person will not be treated as having failed to make required disclosures to a responsible plan fiduciary as long as the person made disclosures in accordance with a good faith, reasonable interpretation of the law.

This Compliance Overview provides a summary of the disclosure requirements, including applicable content and timing requirements, as well as a sample form which requires customization.

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