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Tri-Agencies Release Guidance for Group Health Plan 'No Gag Clause' Attestations
Proskauer [Guidance Overview] Mar. 9, 2023 "Self-insured plans may contract with a third-party administrator to submit the attestation on the plan's behalf; however, the obligation to make a complete and accurate attestation ultimately remains with the plan, not the TPA. For fully-insured plans, while the plan and the issuer are each required to annually submit the attestation, if the issuer submits an attestation on behalf of the fully-insured plan, both will be deemed to have satisfied the attestation requirement." |
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