From the Desk of Allison Johnson - Broker Commission Disclosures
(Posted on 12/21/21)
2021 has certainly been a strange year. Here we are at the end of it, and all we’ve been talking about for weeks is the new CAA Broker Commission Disclosure requirements. I know it sounds like a lot, but I promise it isn’t as bad as it seems. Here are the top things you need to know to save your sanity-

1- The disclosure requirement applies to contracts executed on or after 12/27/21. That means that you should send them to any 12/28 and 1/1 groups you have new or renewing, even if you’ve already wrapped up what you’re doing.
2- Applies to all group “health” plans- that includes dental and vision, as well as self-insured plans. It does not apply to individuals.
3- Brokers who expect to earn $1000 or more in commission or fees must provide a written disclosure to their clients.
4- You can use the commission schedule for the disclosure, such as 4.1% or $34 PEPM.
5- NAHU has a great resource center on their website, including various disclosure templates and recorded webinars you can watch if you’d like more information.
6- The guidance on delivery and timing is vague. As with everything, it’s best to err on the side of caution. Disclosures should be sent before the effective date, and we recommend you require signature if it’s mailed, or a read receipt on an email.

The CAA still has a few provisions with rules that are yet to be written, so if there are any updates, we will be sure to let you know!