Sample Employer, Inc.

1. “Please send your written compensation disclosure.” Since December 27, 2021, brokers and consultants to group health plans who expect $1,000 or more in direct or indirect compensation must disclose it in writing to the plan fiduciary (ERISA section 408(b)(2)(B), added by the Consolidated Appropriations Act, 2021). Compare it with the amounts above.
2. “How are you paid on each line of coverage?” A percentage of premium rises when premiums rise; a flat per-employee-per-month amount doesn't. Ask which applies to each contract.
3. “What else do carriers pay you?” Bonuses, overrides and contingent or incentive payments often show up as “fees” on Schedule A. Ask whether any depend on volume, persistency or growth with a carrier.
4. “Are you paid anything that isn't on Schedule A?” Fees you pay the broker directly, and payments from TPAs, PBMs or other vendors, may not appear on Schedule A at all.
5. “Which carriers did you take us to at the last renewal, and what came back?” Ask to see the quotes, including the ones you didn't take.
6. “Would you work for a flat fee, and what would it be?” Many brokers offer fee-based arrangements with commissions removed or credited back.
7. “When will we see our renewal, and what's the plan if it comes in high?” Agree on dates now (see the timeline below).

• One Schedule A per insurance contract. The insurer fills it in and gives it to the plan; it's filed with the plan's Form 5500. A plan with medical, dental, life and disability coverage from different carriers has several.
• Part I lists each broker or agent the insurer paid in connection with that contract during the plan year: commissions, other fees, the purpose of the fees in the insurer's words, and an organization code (for example “insurance agent or broker”).
• Part III shows premiums for welfare contracts. For most contracts that's the total premium paid to the carrier; for experience-rated contracts it's earned premium, with claims and the carrier's retention shown separately.
• “Persons covered” is the number of people covered by that contract at the end of the policy year, which can differ from the plan's participant count.
• Amounts are for the policy year reported, and the policy year doesn't always match the plan year. A contract that started mid-year can show part-year amounts.
• To see your filing exactly as submitted, search for your plan in the DOL's EFAST2 Form 5500 search.

Most group insurance renews once a year on the policy anniversary. A typical schedule, counting back from the renewal date:

Form 5500 for a plan year is due by the last day of the seventh month after the plan year ends (July 31 for calendar-year plans), or October 15 with an extension. That's why public filings lag a year or more behind today.

This report organizes information from an employer's public Form 5500 filings, as published by the U.S. Department of Labor (EBSA Form 5500 data sets: the Form 5500, Schedule A and Schedule A Part I). We don't change the amounts; we add them up and compare them with other plans in the same data set. Filings that contain obvious entry errors (single amounts over $50 million) are left out of comparisons.

The percentages are positions within a comparison group (“higher than X% of similar-size plans”), not judgments about whether any amount is reasonable. Compensation varies with coverage, premium, plan design, the number of carriers and the services the broker provides. Schedule A doesn't capture every form of broker compensation.

This is information about public filings, not legal, tax, insurance or investment advice, and not an evaluation of any broker, agent or insurer. Talk to your ERISA counsel or benefits adviser before acting on it. Data is provided as is; public filings contain errors and amendments. Verify anything important against your filed return.

Data: U.S. Department of Labor, EBSA Form 5500 data sets (form year 2024, “Latest” files received through Sep 24, 2026). Comparison groups: 69,135 welfare plans that disclosed broker compensation.