Tag: CMS
Employee Benefits Compliance Brief October 2026
2026 Gag Clause Attestation Deadline Employers sponsoring group health plans should have the Dec. 31, 2026, Gag Clause Prohibition Compliance Attestation (GCPCA) on their year-end compliance calendars. The requirement stems from the Consolidated Appropriations Act, 2021 (CAA), which prohibits group health plans and health insurance issuers from entering into certain agreements that restrict access to…
Compliance Recap February 2024
In early February, a federal class action lawsuit was filed against Johnson & Johnson (JNJ) and its plan fiduciaries, alleging overpayment for prescription drugs within its prescription drug plan. The complaint alleges that under the Employee Retirement Income Security Act of 1974 (ERISA), JNJ’s plan fiduciaries are obligated to diligently compare service providers, seek cost-effective options, and…