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Broker Compensation Disclosure Rule

broker compensation disclosure rule

1.5 minute read

Beginning December 27, 2021, as part of the Consolidated Appropriations Act (CAA), covered service providers (CSPs) like insurance brokers and consultants must disclose all compensation to clients if they expect to receive $1,000 or more in direct or indirect compensation for providing their services. This will allow employers to see exactly how brokers earn money which can help inform plan decisions.

Brokers and consultants will be required to disclose specific information to plan fiduciaries in writing including description of services provided and how compensation will be received. A disclosure must be made no later than the date that is reasonably in advance of the date on which the contract is entered into, extended, or renewed. Plan fiduciaries will be responsible for enforcing these requirements, and they are subject to fines if they don’t report a CSP’s failure to disclose in a timely manner.

In a fully insured plan, the responsibility for plan compliance is usually with the insurance carriers. For self-funded plans, legal responsibility for plan compliance typically falls to the employer. However, many employers with self-funded plans utilize a third-party administrator (TPA), who is better positioned to handle these requirements. Whether you’re fully insured or self-funded, employers should ensure their insurance carrier or TPA is preparing to comply with the new requirements of this new law. If neither is applicable, the employer will need to begin preparations of their own.

Download the bulletin for more details.


National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.

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Steve Smith

Steve Smith

Steve Smith, Employee Benefits Consultant for National Insurance Services, has his energy level permanently set at “high.” His maxim is “work hard, play hard.” Steve’s an expert in getting groups of people working together for a higher cause. Minnesota schools, cities, and counties rely on Steve’s unique and creative ideas of engaging employees in their own health and wellness to lower utilization trends. He has 20+ years in the health insurance field doing compliance, cost mitigation, utilization, analytics, wellness plans, and strategic planning. Steve is a licensed insurance agent and holds the designations for Managed Healthcare Professional (The Health Insurance Association of America), Certified Patient Protection and Affordable Care Act Professional (National Association of Health Underwriters), and Group Benefits Disability Specialist (Hartford School of Insurance). He specializes in Employee Benefits Consulting for Minnesota schools, cities, and counties including fully insured, self-insured, and stop-loss plans.