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Temporary Enforcement Policy on Compensation Disclosures

Temporary Enforcement Policy on Compensation Disclosures

1.5 minute read

Brokers and consultants must disclose any direct or indirect compensation they may receive for referral of services to ERISA-covered group health plan sponsors, effective December 27, 2021.

The Department of Labor announced a temporary enforcement policy for these new requirements in Field Assistance Bulletin No. 2021.03. A person will not be treated as failing to make the required disclosures as long as they were made in good faith, reasonable interpretation of the law.

For purposes of the new disclosure requirements, covered plans include the following:

  • Insured and self-insured group health plans, including grandfathered plans, regardless of size
  • Limited scope dental and vision plans

Qualified small employer Health Reimbursement Arrangements (HRAs) are not covered.

The guidance also addresses how covered providers should disclose compensation amounts that cannot be known in advance.

Download the bulletin for more details.

Download the 2022 IRS Contribution Limits Info Sheet

This blog is intended to be a compilation of information and resources pulled from federal, state, and local agencies. This is not intended to be legal advice. For up to the minute information and guidance on COVID-19, please follow the guidelines of the Centers for Disease Control and Prevention (CDC) and your local health organizations.

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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Ken Zastrow

Ken Zastrow

Ken Zastrow enjoys establishing a strong rapport with his clients. He believes that education is key in helping them understand their benefit plans. Ken has a strong background in both active and post-employment benefit strategies. As Employee Benefits Consultant at National Insurance Services, Ken is responsible for the overall assessment and management of all an employer’s benefit plans including claim reconciliation, policy changes, renewals, and medical and dental analytics. He is also well versed in compliance, benefit integration, and early retiree benefits. Ken is a licensed health and life insurance agent, working with schools, cities, and counties in the Midwest Region.