CAA compliance refers to disclosure requirements under Section 202 of Division BB of the Consolidated Appropriations Act, 2021, which amended ERISA §408(b)(2) to mandate that brokers and consultants fully disclose all compensation connected to their recommendations, in effect since December 27, 2021.
A plan fiduciary is expected to review the disclosure for completeness; if it's incomplete and not corrected within 90 days of a written request, the plan sponsor must report the failure to the DOL. This is a genuinely low-volume search term with disproportionately high relevance to the Broker/Consultant audience, since "CAA-defensible ROI" has become the standard a broker's own reputation is measured against at every renewal.
Per ERISA Section 408(b)(2)(B) as amended by the CAA, brokers and consultants expecting $1,000 or more in compensation from an ERISA plan must disclose all direct and indirect compensation tied to every recommendation, effective for arrangements entered or renewed since December 27, 2021.
The employer fiduciary must request the missing information in writing. If the broker doesn't respond within 90 days, the plan sponsor is required to report the failure to the Department of Labor.
Because compensation disclosure is now mandatory and reviewable, a broker's recommendation needs defensible, evidence-based ROI behind it. A vendor that brings real utilization data and reporting makes that case easier for the broker to make to their client.
Every term here points to the same gap in healthcare access. See how the CareStation closes it.
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