Tag: Gag Clause Attestation
Compliance Recap | November 2025
THE ANNUAL GAG CLAUSE ATTESTATION DUE DEC. 31, 2025 Under the rules adopted by Congress in the Consolidated Appropriations Act, 2021 (CAA), group health plans and health insurance issuers of both fully insured and self-funded plans must certify that their contracts with providers, networks, third-party administrators (TPAs), pharmacy benefit managers (PBMs), or other service providers…
Compliance Recap | September 2025
UNDERSTANDING AND DISTRIBUTING MLR REBATES Insurance carriers must issue Medical Loss Ratio (MLR) rebates by September 30 when too much of the prior year’s premiums went to administrative costs or profit instead of claims and quality improvements. Employers who received MLR rebate checks will need to determine how much—if any—belongs to the plan and its…
Compliance Recap December 2024
TWO BILLS IMPACTING ACA REPORTING REQUIREMENTS Two recent bills signed into law by President Biden are set to ease the Affordable Care Act (ACA) reporting requirements for employers. The Paperwork Burden Reduction Act and the Employer Reporting Improvement Act introduce significant changes to the way employers handle Forms 1095-B and 1095-C, used to report health…
Gag Clause Attestation Deadline
As the year comes to an end, a crucial compliance deadline looms for employers with health plans. Under the Consolidated Appropriations Act (CAA), health plans and insurance issuers must submit a Gag Clause Compliance Attestation by December 31, 2024. Since its enactment in 2020, this regulation prohibits health plans from including gag clauses—provisions that limit…