To Disclose or Not to Disclose: Key Takeaways from the CAA's New Broker and Consultant Compensation Disclosure Requirements

[...]plan sponsors and administrators, as well as health plan brokers and consultants, should familiarize themselves with these new disclosure requirements as soon as possible so to ensure timely compliance. [...]the No Surprises Act institutes certain requirements for health plans and issuers intended to protect against surprise medical bills, enable care cost comparisons, increase transparency and enable patient awareness, many of which become effective or enforceable in 2022.1 For instance, effective January 1, 2022, providers must not "surprise" balance bill in certain instances when the patient has not provided written consent, including when receiving emergency services from an out-of-network provider or facility, or care from an out-of-network provider at an in-network hospital, hospital outpatient department, critical access hospital, or ambulatory surgical center. [...]the below key takeaways offer a summary of the new broker and consultant compensation disclosure requirements most anticipated to substantively impact ERISA group health plan sponsors and administrators, as well as health plan brokers and consultants, and necessarily do not cover every provision nor every nuance or exception in the provisions covered. [...]an employee benefits attorney should be consulted in connection with interpreting and implementing the requirements, particularly as the specific plan, service provider, form of services and compensation will dictate the appropriate disclosure.