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Don't Choke on the Gag Clause Prohibition Compliance Attestation Requirement of the CAA
Bond, Schoeneck & King 
[Guidance Overview] Sept. 14, 2023 "Because the group health plan is ultimately responsible for the submission, an employer who contracts with a third-party administrator to complete the attestation on a [self-insured] group health plan's behalf should consider adding contractual language to the agreement providing the employer with protections in the event that the filing is not performed correctly.... For fully insured group health plans, both the insurer and the group health plan are required to annually submit a gag clause attestation." MORE >> |
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