On Friday, July 9, NADP sent comments to the U.S. Department of Labor seeking clarity on the scope of requirements for broker and consultant disclosures in the No Surprises Act. The law, passed as part of Consolidated Appropriations Act, 2021 in December 2020 includes requirements that “covered service entities” (brokers and consultants) disclose direct and indirect compensation to a “responsible plan fiduciary.” However, because of conflicting definitions in the law, there is uncertainty over the inclusion of dental benefits in the requirements for brokers.

NADP sought clarity from the Department and will continue to engage on the issue as implementation guidance is developed for the No Surprises Act.  For questions please contact Owen Urech.

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