Aries insurance services, a division of URL.
Health Plan Options

 

CONSOLIDATED APPROPRIATIONS ACT (CAA) UPDATE

New Broker/Consultant Compensation DisclosuresThe Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA), signed into law on December 27, 2020, imposes new compensation disclosure requirements on brokers and consultants to group health plans covered by the Employee Retirement Income Security Act of 1974 (ERISA).ACA Individual Market ImpactsTitle II, Section 202 of the CAA created disclosure requirements of compensation paid to health insurance brokers and consultants for individual plan enrollees.  The disclosure must be provided by health plan issuers prior to the individual finalizing plan selection and when confirming the individual’s enrollment.   In addition, health plan issuers must report direct or indirect compensation the paid to a broker associated with enrollment to the Department of Health and Human Services (HHS).   To comply with the disclosure requirement, we are asking that brokers selling Highmark individual plans for 2/1/22 effective dates and beyond provide their clients with one of the following:

  • Our website link that displays commission rates
  • A copy of our brochure that will include the website link

These resources will be shared with you in the near future.  In addition, we’ll be asking our brokers who sell individual plans to acknowledge that they have reviewed the proposed rule “Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement”( 86 FR 51730) and understand the compensation information they need to provide.   Thank you for your support as we work to implement new requirements related to this proposed rule.   Small, Middle and Large Group Market ImpactsThe group market disclosure requirement under the CAA is effective beginning 12/27/21.  It is the responsibility of the broker to disclose the direct or indirect compensation received in accordance with the requirements of the CAA.  We strongly encourage you to work with your legal team to ensure that you are compliant with the new requirements.