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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
  • Dental and vision plans
  • Health Reimbursement Arrangements (HRAs)
  • Health Flexible Spending Accounts (FSAs)

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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Steve Smith

Steve Smith

Steve Smith is a powerhouse of energy, living by the mantra "work hard, play hard." As an expert in uniting teams for a greater purpose, Steve's innovative and creative strategies in employee health and wellness are game-changers. With over 25 years of expertise in health insurance, covering compliance, cost mitigation, utilization, analytics, wellness plans, and strategic planning, Steve is the go-to expert for driving down utilization trends and fostering a culture of well-being. His clients trust him to deliver exceptional results, making him an invaluable asset in the industry. As an Employee Benefits Consultant, Steve specializes in health care consulting for Minnesota public sector organizations including fully insured, self-insured, and stop-loss plans. 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).