Brokers, Consultants & Benefits Advisors

Brokers, consultants and benefits advisors are the intermediaries that employers hire to choose, buy and run their health benefits. They sit between the employer and the health plan, and for most companies they are the single most influential voice in which plan gets bought.

How it works

The channel runs along a spectrum, and the labels are loose:

Broker / agent. Licensed by the state to sell insurance. Typically works with smaller employers, handles the transaction (quoting, binding, renewals), and is paid by commission from the carrier. Most US employers buy through a broker.
Benefits consultant/advisor. Works further up-market with mid-size and large employers. Sells strategy, data and plan design rather than just a policy and often charges the employer a flat fee instead of commission. Sometimes the flat fee can be charged alongside a commission. A benefits consultant/advisor often stays involved year-round. The big national firms operate here.
General agent (GA)/wholesaler. Sits behind the broker and aggregates small-group business across carriers. The retail broker you meet may be supported by a GA you never see, and the GA also takes a cut.

For a self-funded employer, the advisor's job is typically wider: they help select the TPA, the PBM, the stop-loss carrier and the network, and increasingly the point-solution vendors (telehealth, chronic care, navigation). The advisor effectively assembles the plan from parts.

How brokers and consultants get paid

Compensation comes in three flavors:

Commission — a percentage of premium paid by the carrier. For fully-insured medical it's typically 2–10% of premium. Small-group medical is often a fixed per-employee-per-month (PEPM) amount (roughly $25–$40 PEPM is typical). Ancillary lines (dental, vision, life, disability) pay richer percentages (frequently 5–15%). There are some other groups that can and do pay much more.
Overrides/contingent compensation/bonuses — these are extra payments from carriers tied to the broker's total book of business. It's usually made up of how much volume they place, how fast it grows and how profitable (low-loss-ratio) it is. The employer almost never sees this layer, and it's a negotiation directly between the broker and carrier.
Fee-for-service — a flat or hourly fee paid by the employer.

Because commission is a percentage of premium, broker pay rises when premiums rise so compensation and the client's cost-control objective track along different lines. This is an inherent feature of percentage-based pay, and it is precisely what the fee-based and fiduciary arrangements below are structured to align.

Where incentives meet

Percentage-of-premium compensation ties broker pay to premium levels, to headcount and dependents, and to carrier mix. That structure has real benefits. For example, it allows brokers to serve small employers at no direct out-of-pocket cost to them. However, it also means the advisor's economics and the client's cost-control goals are not automatically aligned. Therefore contingent overrides and carrier bonuses add a layer the employer may not readily see. This is exactly the information the CAA disclosure rule (below) is designed to surface. It is also the space the fee-only and fiduciary models are built to serve: for a self-funded employer weighing how much stop-loss to carry or which PBM to select, full visibility into how each recommendation is compensated is what lets the buyer treat the advice as independent.

The disclosure rule (CAA, 2021)

The Consolidated Appropriations Act, 2021 amended ERISA 408(b)(2) to force transparency. Brokers and consultants who reasonably expect $1,000 or more in compensation for their services to an ERISA group health plan must give the plan fiduciary (the employer) a written disclosure of all direct and indirect compensation. This includes overrides, bonuses, and payments from carriers and vendors before the contract is entered into, extended or renewed. The requirement took effect for arrangements on or after 27 December 2021, and the DOL issued enforcement guidance in Field Assistance Bulletin 2021-03.

The rule does not ban indirect compensation; it requires the broker to name it. Whether employers read and act on those disclosures is a separate question.

Why it matters

Whoever controls the broker channel controls plan selection. Carriers and TPAs compete fiercely for broker mindshare because the broker is who the employer trusts, not the carrier's own sales team. New entrants (a startup TPA, a pass-through PBM, a navigation vendor) live or die on broker distribution. If brokers don't include them in the quote, employers never see them.

Zahid's take: Distribution economics are decisive

Having built in this space, my read is that the broker authorizes the signature on the cheque, not the employer. This is true for mist benefits products, and a go-to-market strategy should treat the channel accordingly. Of course, there are exceptions and market behavior is always evolving. The economics for distribution are decisive: a product that makes the broker look good to their client whilst respecting the broker's compensation travels much further than one that routes around the channel.

The most interesting emerging door is the fee-only/fiduciary advisor segment that serves self-funded mid-market employers who prioritize transparency and measurable outcomes. Those buyers actively want data, benchmarking and results to make their decision which offers a natural wedge for an AI-driven analytics or UM-cost-modelling product.

Another observation worth highlighting for anybody coming from an insurance or risk background is that the role of brokers in US Healthcare overlaps significantly with the role of brokers elsewhere. The incentives and behavior is also largely the same. Prior to Anterior, I worked in underwriting risk for Aerospace and Drones, where brokers largely played a very similar role. And building products and experiences which respected the broker's role in transactions only helped the company continue dominate in the space.

Numbers that matter

2–10% of premium: typical fully-insured medical commission.
$25–$40 PEPM: common small-group medical commission band.
5–15%+: ancillary-line commissions (dental, vision, life, disability).
$1,000: CAA disclosure threshold for ERISA group health plan compensation.
27 Dec 2021: CAA broker-compensation disclosure effective date.

Sources

DOL/EBSA, Field Assistance Bulletin 2021-03 and CAA broker compensation disclosure release — https://www.dol.gov/newsroom/releases/ebsa/ebsa20211230
EPIC Insurance Brokers, "DOL Provides Q&As on CAA Broker Compensation Disclosure" — https://www.epicbrokers.com/insights/dol-provides-qas-caa-broker-compensation-disclosure-requirements/
NABIP, "Broker Compensation Disclosure Requirements under the CAA, 2021" — https://nabip.org/media/6779/broker_compensation_group_112921.pdf
Nava Benefits, "Employee Benefits Broker Commissions: How Do Brokers Make Money?" — https://www.navabenefits.com/resources/employee-benefits-broker-commissions
KFF, Employer Health Benefits Survey — https://www.kff.org/health-costs/2025-employer-health-benefits-survey/