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Broker compensation template, 408(B)(2). How brokers need to disclose their compensation. - Shared screen with speaker view
Stacey Gilbert
39:57
Is this recorded
Dana Bonanno
40:07
yes
Richard Zeitler
40:30
If we wish to review it later, will it be sent out?
Dana Bonanno
40:48
Misty indicated that ys
Dana Bonanno
40:53
yes
jerry carlson
41:07
What about 1/1/22 renewals?
Colleen Hernandez
42:07
What about renewals that do not require any paperwork to renew?
Robert W Locke Sr
42:55
I am not getting any audio. It just abruptly stopped.
Dale Vargas
43:11
How do you account for the general agent's override in the broker disclosure?
Lisa Howard
43:35
If an agent shares comp by giving a bonus to an admin does this need to be disclosed or just who the commission is paid to?
Karen Riley
43:50
What if we don't know the commission prior to getting the employer application completed?
Thomas White
44:31
Does this include Voluntary Plans?
Rise Kieren
44:57
Would the $1,000 be an aggregate of all plans that are provided to the client or is it on a per plan basis?
Tony Martinez
45:22
Is this is for health Insurance products only?
Debbie Fleck
46:35
If we just list the commission percentage is that adequate. Or do we have to list the actual dollar as we don't what future enrollment will be or do we know who will elect what line? Is this ALL lines of coverage.
Katie Lau
46:38
Small group is 'age rated', so what information or how to report?
Anya Simpson
46:58
is life and di subject to commission disclosure?
Debbie Fleck
47:59
What about Colonial, AFLAC, and Vol. Life
Donna Pomerantz
48:42
Is this for small and large group in Maryland or just large group please? Thank you.
Ruby Pierce
49:07
If carriers pay bonuses, but as a small agency we know we will not qualify, do we need to disclose any information about dollars we will not receive?
Debbie Fleck
49:07
Will carriers begin to include the disclosure within their renewal?
Bob Adams
51:22
Some employers add employees without our knowledge. What then?
Karen Riley
51:31
If we offer free resources to clients, do we have to disclose this (ie. HR & on-line portal)
Lisa Howard
51:38
What period of time is the $1000 based on?
Anya Simpson
52:12
which law put this rule into effect?
BJ WAKELY
52:17
Is this for individual policies too?
Dana Bonanno
53:40
confused
Debbie Fleck
54:18
Do you have a sample disclosure form.
Stacey Kindsvater
54:34
You said that disability and life is excluded but then said it's not product related and that ALL compensation is included...
Heidi Hammond
54:44
yes they are going to give you a template.
Heidi Hammond
54:50
it is for group
Misty Baker
54:54
individual plans and short term medical disclosures are provided by the carrier
Leslie Swartzwelder
55:10
I'm for the government and I'm here to help!
Misty Baker
55:11
Template in the next few slides
Sarah Felts-Smith
55:32
May we include the carrier commission schedule with this disclosure form, when sent to the client?
Misty Baker
55:59
Young Kim...no. If you have the plan sold & signed before 12/27, no disclosure
Diane Peralta
56:00
You'll be providing the PEPM rate or the % of comp, if that comp is more than $1K.
Dana Bonanno
56:09
id like to know how they are going to monitor this LOL
Bruce Weinstein
56:17
Would we include gross comp? i.e. we receive 100 total income and have a partner broker we share 50/50 with would the disclosure be 100 or 50?
Jessica Gardner
57:06
Is it $1,000 combined for all lines/plans, or per line of coverage? So we make $2k for medical, we disclose. If we make $150 for COBRA, do we disclose that to or could we leave that off?
Tom Street
57:30
So hospitals, PBMs and insurance companies can continue to operate with impunity and the brokers get stuck with this BS, got it.
Debbie Fleck
58:04
But as long as we do our 2022 renewals before 12/27 we don't have to do it for them but going forward would apply. Is that correct? Do you expect further guidance as this sounds like a lot of extra work and it may get changed before we need to begin.
Dana Bonanno
58:40
so does it have to be disclosed for all clients/prospects by 12/27 or just as they renew?
Kallen McCoy
58:48
If we have subcontractors or split commission - does each broker need to fill out a form for their individual direct and indirect compensation?
Debbie Fleck
01:02:12
Is the $1,000 all inclusive of Medical, Dental, & Vision or is it $1,000 per line. What do we do in situations where it is a sliding scale (not uncommon for vision).
German Arguedas
01:02:18
large gruop renewals include comp %. would this meet teh requirment
Ruby Pierce
01:02:38
If I receive a 5% commission, do I need to estimate a dollar amount for the year?
Karen Riley
01:03:33
how are over-rides reported?
Kerstin Williamson
01:03:44
Regarding indirect compensation, is it reasonable to disclose compensation based on the coverages likely to be placed versus all 30 coverages shown on a spreadsheet?
Christina Bull
01:03:54
Is a producer service fee direct or indirect?
Dana Bonanno
01:04:03
eh em...there are no overrides 😇
Rob Cannon
01:04:05
What if commission from carrier comes through BenefitMall?
Debbie Fleck
01:04:38
Is this for all options shown or just the option selected by the carrier -
Dana Bonanno
01:05:44
this is a good question
Dana Bonanno
01:05:45
‘I Rebel Because My Mom Was Too Strict On Me,’ Says Teen
Joshua Feiman
01:07:10
What if the charge for the "Enrollment system" is a pass through. If the broker is charged $1PEPM and then they charge the client the $1 PEPM?
Tom Street
01:07:32
"Reasonable", so rent control basically.
Debbie Fleck
01:07:37
I thought I heard Misty say do not include Life & Disability but David say to include Life & Disability. Please clarify as I misunderstood.
Tara Langston
01:08:04
Is it $1000 per group or per line over coverage or service? If you have 3 lines of coverage and each is under $1000 do you have to disclose?
Dana Bonanno
01:09:27
so does it have to be disclosed for all clients/prospects by 1227 or just as they renew
Bruce Weinstein
01:10:17
For clarity... we completed renewals for 11/1 and now for 12/1 are these disclosures held off until next renewal?
Rob Cannon
01:10:43
A carrier may give a bonus for retention to the agency. The agent may have no idea. What does the agent do?
Bob Adams
01:10:54
What happens if the Employer does not send it back to you?
John Edmonds
01:11:15
Wow. Disclosure of any gift, golf, meal? When did we become elected officials?
Dale Vargas
01:11:49
Let's go Brandon!
Bruce Weinstein
01:11:59
Perfect!
Dana Bonanno
01:12:01
LETS GO BRANDON
Sean Mullen
01:12:13
LoL!
Tom Street
01:12:23
So fill out these forms and then send them to your clients if/when they request them or are audited by DOL? got it
Dana Bonanno
01:12:59
OMG
Dana Bonanno
01:13:07
Cant we just do it as a firm?
Dana Bonanno
01:13:13
IE: MABS receives 3%
Karen Riley
01:13:23
Can you point to this section you are discussing
Tom Street
01:13:35
Next up, restaurants disclose how much they paid for their wine list bottles.
Sheila Gaylor
01:13:38
Guys - the bill was passed in Dec of 2020 BEFORE we had to start dealing with LGB .. ugh!
John Edmonds
01:13:50
After I deal with all of the compliance that I don't get paid for, I will start doing my job helping my clients.
John Deem
01:13:51
President Trump signed the CAA. This disclosure requirement was not from Biden.
Sheila Gaylor
01:13:56
To Tom Street - I agree!
Kerstin Williamson
01:14:17
I our agency receives 100% of the commission but then pays a portion out to a sub producer, are we required to disclose the entire (100%) of the commission or only the portion we retain.
Rhonda Peters Titus
01:14:59
Thank you John Deem you beat me to it!
Chris Semmens
01:15:08
Do licensed service staff who are paid a salary have to disclose compensation since it is made up of commissions?
Risa Ziman
01:15:45
IS PEO comp included?
Rob Cannon
01:16:23
If a 1/1/22 Health renewal is automatic with no signature, do we have to disclose?
Dana Bonanno
01:16:35
1. do we disclose the entire commission as a firm or does each assigned agent on the case have to disclose separately -
John Edmonds
01:16:43
It feels like that in an audit if we can show we sent the disclosure that should be good enough, right?
Dana Bonanno
01:16:49
2. do we disclose to prospects/clients by 12/27 or upon their renewal?
Penny Szafran
01:18:34
is this requirement on all size groups?
Alex Kim
01:19:18
Can you post the link to download the template here?
Dana Bonanno
01:19:26
where can we download the template
Chrisje Mays
01:19:36
healthcareexchange.com
Henry Franklin
01:19:46
How would you list a graded commission schedule?
Donna Kolojek
01:19:52
Were to we go to download the template on the website again?
Sam Dale
01:19:55
https://www.healthcareexchange.com/article/broker-compensation-reporting-form
Sam Dale
01:20:03
This is the link
Mike D'Alessandro
01:20:05
Just to confirm, if less than $1K in compensation is received from the group, no requirement for disclosure?
Sam Dale
01:20:29
And the link will be provided on the email.
Kerstin Williamson
01:20:53
Misty: Regarding co brokers disclosures, is this regardless of the agency listed on the application?
Mike Schunk
01:21:28
If I am a co-broker and disclose the full compensation, does the other broker need to disclose?
Alex Kim
01:21:36
Thanks Sam.
Danielle Miller
01:21:45
In addition to the above question - if the co-broker is 1099 not paid by the carrier how is that disclosed?
Jeffrey Susskind
01:21:49
if split 50/50 and commish is $1800, each broker gets $900. So NO letter is required, correct?
Angela Hasenei
01:22:15
If our agency collects 100% commissions but pays out sub agents there portion of the commissions, do the sub agents have to report or just our agency??
Dana Bonanno
01:22:47
IS IT DISCLOSED ON RENEWAL OR JUST AFTER 12/27
Pamela Lamer
01:23:10
On the form is it annually or monthly that is being reported?
ron bedrosian
01:23:54
What happens when a client reduces employee count during the year. My expected commission will be less than initially stated.
jerry carlson
01:24:05
How / When do we report a group that has one line of coverage renewaing in Feb and the rest in July?
Alex Kim
01:25:34
Do we have to do this "every year" or just once after 12/27/21? Assuming no new lines or carriers were sold.
Nancy Riedel
01:26:03
Your referrences to $1,000 do not specify annual or monthly comp, so I assume you mean annual.
Heidi Hammond
01:26:13
annual
German Arguedas
01:26:19
does this include P&C?
Bruce Weinstein
01:26:33
In lieu of a dollar amount you displayed earlier that disclosure can be as an example "3%" does that suffice?
Heidi Hammond
01:26:37
yes
Anya Simpson
01:26:54
does it include life and DI.
Bill Geraci
01:26:56
I listened to a similar webinar conducted by NAHU. This is 1000% better.
Kat Hoi
01:28:39
Will you share this recording and presentation after the meeting?
Thomas White
01:29:20
Sounds like Voluntary Plans are included if you can expect to receive over $1K ….
Nanette Poserina
01:29:31
Renewal means contract renewal date correct?
Rob Cannon
01:30:56
What if it pays 5% and I receive 3%? Do I determine based on my 3%?
Tom Street
01:31:08
This is an ERISA regulation but applies to services outside of ERISA? How does that work.
Jessica Gardner
01:32:08
Sorry if I missed this ...… Is it $1,000 for all lines/plans combined? For example, If we make $800 on medical, $400 on dental, $200 on vision, do we disclose?
April Owens
01:32:18
will this include group voluntary plans or just medical, Dental, Vision
Sam Dale
01:32:23
https://www.healthcareexchange.com/article/broker-compensation-reporting-form
Sam Dale
01:32:29
In case you missed it
Sheila Gaylor
01:33:09
you've done a great job! Thank you!
Lisa Benton
01:33:16
Please, if our agency makes $2000, but I only receive $1000 compensation/commission, how is this handled.
Nancy Riedel
01:34:04
Thanks for the webinar ... very informative!!
Alex Kim
01:34:36
I agree, amazing presentation!
Rob Cannon
01:35:04
Please answer Jessica's question. It is very important.
Penny Szafran
01:35:29
Do you have employer information from DOT that we can provide to the employer on why we are providing this disclosure.
Alex Kim
01:36:04
Do we have to send this form every year?
Esther Glick
01:37:01
Can you please make the answers to all the questions here available to us after the webinar is over?
Thomas White
01:37:25
Thanks - Great Presentation!
Tony Martinez
01:37:29
Thank you both! Well presented and explained.
Richard Zeitler
01:37:40
You too are awesome!!!! Thank you for doing this for us.
Hal Schlenger
01:37:45
Well done -- you've added value to my day
Dana Bonanno
01:37:46
cannot manipulate form
Dana Bonanno
01:37:51
well done
Esther Glick
01:37:52
Many thanks, this was very helpful :)
Jessica Gardner
01:37:57
Maybe y'all should do another one with just questions and answers. :-) Thank you! This is a big one.
Bob Adams
01:37:58
Thank you. Appreciate the info.
Alex Kim
01:38:02
Thank you!
Brenda Bealmear
01:38:03
Thank you!
Kristi Griffis
01:38:09
Thanks so much for the information