The Departments of Labor, Health and Human Services, and the Treasury, with the Office of Personnel Management (the “Departments”) jointly released FAQs About Consolidated Appropriations Act, 2021 Implementation Part 69...more
Our Employee Benefits & Executive Compensation Group discusses new guidance for group health plans and insurers on complying with federal gag clause prohibitions and No Surprises Act requirements....more
As we bid farewell to 2024 and look ahead to the new year, we reflect on the many evolving compliance obligations that health and welfare plan sponsors tackle each year. Although this list is by no means exhaustive, it...more
December 31 is the upcoming deadline to submit gag clause attestations pursuant to the Consolidated Appropriations Act, 2021. When the Consolidated Appropriations Act, 2021 (the “CAA”) was enacted on December 27, 2020, it...more
The U.S. Department of Labor (DOL), the U.S. Department of Health and Human Services (HHS), and the Internal Revenue Service (IRS) have updated the Submission Instructions and User Manual for the Gag Clause Prohibition...more
As employers look back at 2023 and ahead to 2024, there are so many compliance-related items to consider relating to their employee benefit plans. The rules employers are supposed to be complying with keep growing and...more
As part of the No Surprises progeny of legislation seeking transparency in health care, the Consolidated Appropriations Act of 2021 prohibits the use of "gag clauses" in group health plan agreements. All group health plans...more
This is a reminder that a new compliance deadline is on the horizon for group health plans. The Consolidated Appropriations Act (CAA) of 2021 generally prohibits group health plans and health insurance issuers from entering...more
This newsletter provides updates employers should be aware of heading into 2024, including an outline of the updated 2024 retirement and welfare plan limits, instructions related to the “gag order” attestation requirements...more
By December 31, 2023, group health plans and health insurance issuers must submit an attestation to certify compliance with the “gag clause prohibition” under the Consolidated Appropriations Act of 2021 (CAA)....more
The Consolidated Appropriations Act of 2021 generally requires group health plans and health insurance issuers to submit a Gag Clause Prohibition Compliance Attestation (Attestation) each year to demonstrate compliance with...more
By December 31, 2023, health plans and insurers must submit an attestation of compliance with the “anti-gag rules” of the Consolidated Appropriations Act of 2021 (CAA). The rules apply to all agreements entered into on or...more
Under the Consolidated Appropriation Act of 2021 (CAA), group health plans and health insurance issuers are prohibited from entering into agreements with service providers restricting certain information that the plan may...more
Summary - By December 31, 2023, health plans and insurers must submit an attestation of compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA). The rules apply to all agreements entered into...more
On February 23, 2023, the Departments of Labor, Health and Human Services, and Treasury(collectively the “Departments”) released guidance to initiate the enforcement provisions related to the “gag clause” prohibitions...more
When the Consolidated Appropriations Act, 2021 (the “CAA”) was enacted on December 27, 2020, it included a provision that prohibits group health plans and health insurance carriers from entering into certain agreements that,...more
With each new year, new legal obligations for employers sponsoring group health plans seem to arrive. This article provides a brief overview and reminder of some of the new key requirements for 2022, many of which we have...more
Summary - Health plan vendors sometimes impose contractual restrictions on the disclosure of data that they consider to be confidential or proprietary. A number of new rules aim to foster transparency and require...more
The Consolidated Appropriation Act of 2021 was signed into law on December 27, 2020 and is an impressive 5,593 pages. According to the Senate Historical Office, the Act is the longest bill ever passed by Congress. Buried...more