Attention ALL Brokers working in Group Health and/or Individual Health Markets:

Broker Compensation Disclosure Requirements

Section 202 of the Consolidated Appropriations Act, 2021 (“CAA”), requires entities providing brokerage and consulting services (referred to collectively as “covered service providers”), including their affiliates and subcontractors, who expect to receive $1,000 or more in direct or indirect compensation, to provide plan fiduciaries with a written disclosure “reasonably in advance of” when the contract is entered, extended, or renewed. The effective date of the requirement is December 27, 2021 and applies to contracts executed on or after December 27, 2021.

Included you will find the carrier guidelines for Individual and Family plans and separate group health broker guidelines which includes a commission disclosure template.   Please note:  The CAA’s disclosure requirements apply to any contract executed, extended or

renewed on or after December 27, 2021