CAA 2021 Broker Compensation Disclosure
  • THE WHOLE PERSON

  • Benefits Broker Request for Proposal (RFP)

  • CAA 2021 BROKER COMPENSATION DISCLOSURE FORM

  • This form must be completed by all bidders as part of the RFP response. The Consolidated Appropriations Act of 2021 (CAA 2021) requires brokers and consultants who provide services to group health plans to disclose all direct and indirect compensation. Failure to complete this form will result in disqualification of your proposal.
  • SECTION 1: BROKER/CONSULTANT INFORMATION

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  • SECTION 2: SERVICES TO BE PROVIDED

  • SECTION 3: DIRECT COMPENSATION

  • Direct compensation includes commissions, fees, or other payments paid directly to you by The Whole Person, insurance carriers, or vendors for the placement and servicing of group health plan coverage.
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  • Compensation Type Examples: Base Commission %, PEPM Fee, Flat Fee, Per Transaction Fee
  • SECTION 4: INDIRECT COMPENSATION

  • Indirect compensation includes any payments or benefits received from sources OTHER than The Whole Person that are related to services provided for The Whole Person's group health plans. This includes:
    • Contingent commissions, bonuses, or profit-sharing from carriers
    • Volume bonuses, growth bonuses, or retention bonuses
    • Overrides or commissions from downstream providers (TPAS, PBMs, vendors)
    • Service fees, consulting fees, or finder's fees from vendors
    • Non-monetary compensation (trips, gifts, awards, sponsorships, training)
    • Marketing fees, advertising allowances, or co-op funds
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  • SECTION 5: CONTINGENT OR VARIABLE COMPENSATION

  • SECTION 6: TERMINATION COMPENSATION

  • SECTION 7: CONFLICTS OF INTEREST

  • SECTION 8: AFFILIATES AND SUBCONTRACTORS

  • SECTION 9: CERTIFICATION AND ACKNOWLEDGMENT

  • I certify that the information provided in this disclosure is accurate and complete to the best of my knowledge as of the date below. I understand that:
    1. This disclosure is required by the Consolidated Appropriations Act of 2021 for all brokers and consultants who expect to receive $1,000 or more in compensation.
    2. I must update this disclosure within 60 days of any material change in compensation.
    3. I must correct any inadvertent errors or omissions within 30 days of discovery.
    4. I must respond to any written request for information from The Whole Person within 90 days.
    5. Failure to provide accurate disclosure may result in disqualification and may constitute a prohibited transaction under ERISA.
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  • This form must be completed and submitted as part of your RFP response. Failure to provide this disclosure will result in automatic disqualification of your proposal.
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