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Employer Compliance Guide to the CAA's No Gag Clause and Attestation Requirements

October 02, 2023

Join the NFP Compliance and Cost Containment Strategies teams for a discussion on employer compliance with the No Gag Clause and attestation requirements of the Consolidated Appropriations Act of 2021 (CAA) which apply to both fully and self-insured group health plans.

The NFP team will outline the rules and purposes of the No Gag Clause and attestation requirements as well as the related CAA Transparency in Coverage self-service tool requirements. The discussion will then turn to the steps employers must take to comply with the No Gag Clause and Attestation requirements, including identification of applicable plan types and contracts, engagement of TPAs and other service providers, identification and removal of problematic gag clauses, and completion of the annual attestation (due at the end of 2023 and annually thereafter).

Agenda

  • CAA Gag Clause Prohibition
    • Basics and Background
    • Specific Requirements and Applicability
    • Employer Action Plan
    • NFP Resources and Role
    • Attestation of Compliance
    • Key Takeaways
  • TiC Internet Self-Service Tool
    • Review of Requirement
    • 2024 Implementation
  • Final Takeaways
  • Questions?

Employer Compliance Guide to the CAA’s No Gag Clause and Attestation Requirements


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