Independent Insurance Agents & Brokers of America Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule
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On behalf of the
Founded in 1896, the IIABA is the nation's oldest and largest association of independent insurance agents and brokers, representing more than 25,000 agency locations under the Trusted Choice brand.
Trusted Choice independent agents offer consumers all types of insurance--property, casualty, life, health, employee benefit plans and retirement products--from a variety of insurance companies.
IIABA strongly opposed the enactment of Section 2746 of the Public Health Service Act by
We also offer the following comments:
* IIABA appreciates that the notice of proposed rulemaking notes that these disclosure obligations and the responsibility for satisfying them falls only on issuers. There are many parties, including individual insurance producers, who have commented on the proposed rule that appear to believe the compliance obligation will apply to them. For this reason, HHS may wish to reiterate that these new requirements and the costs of compliance associated with them apply to issuers.
* The notice of proposed rulemaking also makes the assumption that compensation disclosures to potential policyholders prior to finalizing enrollment would be made by agents and brokers on behalf of issuers. We appreciate, however, that the notice also points out that issuers are the parties responsible for compliance and presumes that issuers will be the entities providing compensation disclosures on documentation confirming enrollment and on renewal notices.
* The proposed rule's definition of and use of the phrase "commission schedule" is somewhat confusing and does not make clear what is intended. An issuer that pays an insurance producer a commission of X% for enrolling an individual in health coverage should be able to satisfy the new obligation by disclosing that a commission of X% was paid without also having to provide a more formal and potentially confusing "commission schedule." Providing a commission schedule to policyholders could be a way to satisfy the obligation, but it should not be required in all instances and scenarios.
We would like to thank you for the opportunity to express the views of independent insurance agencies on this issue. The IIABA appreciates the effort that has gone into this proposal. Please contact
Sincerely,
Assistant Vice President, Federal Government Affairs
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The proposed rule can be viewed at: https://www.regulations.gov/document/CMS-2021-0147-0001
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