PODCAST: Williams Mullen's Benefits Companion - Gag Clause Prohibitions
On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt discusses prohibitive gag clauses under the Consolidated Appropriations Act (CAA). While intended to promote transparency, not all gag clauses are...more
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
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
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
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
The time may have come to add a welfare plan committee to your company’s governance of employee benefit plans. New legal obligations and other developments impose fiduciary risks for welfare plans similar to what already...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
Effective December 27, 2020, the Consolidated Appropriations Act, 2021 (“CAA”), as part of its transparency in health care protections, prohibits group health plans and issuers from entering into agreements that directly or...more
Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more
Under the Consolidated Appropriations Act, 2021 (CAA), group health plans and health insurance issuers are required to annually attest that they are in compliance with the CAA’s gag clause prohibition. On a high level, the...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