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First Gag Clause Attestations Due December 31, 2023: What Group Health Plan Sponsors Need to Know
Hunton Andrews Kurth LLP 
[Guidance Overview] May 19, 2023 "Plan sponsors and carriers of fully insured plans are both required to submit a [Gag Clause Prohibition Compliance Attestation (GCPCA)]. [FAQs Part 57] provide that if the insurance carrier submits the GCPCA on behalf of the plan, the Departments will consider the plan (and insurer) compliant. Sponsors of fully insured plans, however, should confirm that the carrier will be submitting the GCPCA on the plan's behalf." MORE >> |
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