Public Agency Benefits Intermediary Compensation Disclosure Act

The law exposes direct, indirect, and financial-interest conflicts before local governments make employee-health-benefit purchasing decisions. It extends transparency protections to public-sector health plans that do not fall under federal ERISA rules.

What the law does ​

• Requires covered brokers, agents, consultants, and advisors expecting at least $1,000 in compensation to disclose expected direct and indirect pay, including pay to affiliates, subcontractors, and related parties.
• Requires disclosure of compensation sources, amounts or good-faith estimates, payment formulas, noncash benefits, termination pay, ownership interests, and material business relationships with recommended carriers and vendors.
• Requires disclosures with a provider’s first formal written offer, at least 60 days before extensions, renewals, or material amendments, annually for ongoing services, and after material changes, errors, or estimated-pay true-ups.
• Bars providers from accepting undisclosed compensation or restructuring, relabeling, or routing compensation to evade disclosure.
• Requires providers to retain supporting records for at least three years and make them available upon request to specified enforcement officials.
• Applies to contracts and arrangements entered into, extended, or renewed on or after January 1, 2028.

Who it affects ​

• Local public agencies and their group health plans, including counties, cities, school districts, community college districts, special districts, joint powers authorities, and public employee benefit trusts.
• Brokers, agents, consultants, advisors, and related service providers involved in public employee health-benefit arrangements.
• Carriers, pharmacy benefit managers, third-party administrators, vendors, and pooled purchasing arrangements whose payments or relationships must be disclosed.