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.
The provision amended ERISA §408(b)(2) to require brokers and consultants advising group health plans to fully disclose all direct and indirect compensation connected to their recommendations.
The plan fiduciary is responsible for reviewing that disclosure for completeness. If it's incomplete, the fiduciary must request the missing information in writing; if it isn't corrected within 90 days, the fiduciary must report the failure to the DOL.
For brokers and consultants, CAA compliance isn't just a paperwork requirement—it's the baseline every recommendation now gets measured against. Because full compensation disclosure is mandatory, a recommendation can't just be a preference call; it has to hold up as evidence. This is what "CAA-defensible ROI" means in practice, and it's become the standard a broker's own reputation is judged against at every renewal.
This is where built-in reporting matters for brokers working with the OnMed CareStation®: utilization data and ROI reporting give a broker a documented, evidence-based case for the recommendation itself—the kind of record that holds up when a client's finance team or a plan fiduciary is evaluating why a solution was recommended and what it delivered. (This supports the broker's case for the recommendation; it does not substitute for a broker's own compensation-disclosure obligations under §408(b)(2), which remain the broker's responsibility.)
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 requirement applies whether compensation is structured as a fee or a commission.
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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