On December 27, 2020, the Consolidated Appropriations Act, 2021 (CAA) became law and contains several provisions related to business transparency.

The No Surprises Act Section 202(c) of the CAA is focused on enhancing the compensation disclosure rules for group health plans, individual brokers, and consultants. These new disclosure requirements bring group health plans more in-line with the disclosure rules under Section 408(b)(2) of ERISA issued in 2012 that apply to retirement plans (e.g.401(k) plans).  This includes all forms of compensation, including standard ongoing compensation, bonuses, finder’s fees, prepaid (advanced) commissions, payments made by third parties, incentive programs not solely related to the plan, etc.

The new ERISA disclosure requirements apply to any covered services provider that reasonably expects to receive $1,000 or more in direct or indirect compensation for brokerage or consulting services provided to an ERISA-covered group health plan.

The following constitutes Waugh Agency LLC’s (Matt Waugh NPN#8871397) disclosure of direct and indirect compensation the Broker will receive or reasonably expects to receive for the 2022 calendar year in connection with the below referenced services

• Placement Services (e.g., assessing and reviewing current plans)
• Conduct renewal analysis Negotiating with carriers
• Enrollment services (e.g., eligibility, on-boarding, additions, and deletions)
• Benefits portal configuration and maintenance
• Serve as liaison between group client and the carrier 
• Assist in billing collection and resolution
• Participate in eligibility maintenance and answer plan related questions 
• Provide regulatory support and guidance
• Assist in preparation of insurance related forms (e.g., Form 5500)
• Referral related services
• Facilitate retention of TPAs or other service provides
• Coordinate in acquisition of value-added services (e.g., HR Support, wellness resources) 

Direct & Indirect Compensation

The Company reasonably expects to receive direct compensation for the placement of the below lines of coverage in the form of either a per employee per month (“PEPM”) fee, a commission fee, or flat fee, directly from the Client. Please click on the insurer or vendor name for access to the compensation details.

• Blue Cross Blue Shield of Massachusetts
• Harvard Pilgrim
• Tufts Health Plan
• Health New England
• Health Services Administrators
• Lincoln Financial
• Sun Life
• Guardian Life 
• BCBS of California
• UnitedHealthcare
• Oscar

 Other Compensation

The Broker may earn additional compensation from any of the above referenced insurers, vendors, or other third parties that cannot be calculated as of the time this disclosure is made to you, or prior to the date the Broker’s executed, extended, or renewed contract with you is effective. For example, the Broker may receive additional compensation contingent upon certain conditions being met, including, but not limited to, profitability, growth, churn/retention, or the volume of services provided.

Compensation may be in the form of additional commissions, bonuses, or benefits (“compensation”). Furthermore, we may receive corporate sponsorships for webinars, training or other programming we provide for you and other clients, or for our own internal trainings. Whether we receive any of the above referenced compensation, or how much that compensation may be, cannot be discerned at this time.

Should you have any questions about any of the above information or require additional information, please don’t hesitate to contact us.

Waugh Agency, LLC provides an elite level of service for your company’s group health insurance, benefits, and compliance programs.