2021 Consolidated Appropriations Act Compliance Checklist for Plan Sponsors

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On December 27, 2020, former President Trump signed the Consolidated Appropriations Act, 2021 (the “CAA”) into law. The CAA includes numerous provisions that impact employer-sponsored group health plans, including the much-anticipated rules regarding surprise medical bills. While some requirements have already taken effect, many of the new provisions take effect December 27, 2021 and for plan years on or after January 1, 2022, not giving employers and their service providers much time to gear up for those extensive changes. Accordingly, employers may want to start preparing for these new rules sooner rather than later. See our CAA chart that provides a more detailed summary of the principal requirements under the CAA that apply to employer-sponsored group health plans. Given the tight timeframe, we hope to get guidance from the government as soon as possible.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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