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Gag Clause Prohibitions in ERISA, the Internal Revenue Code and the Public Health Service Act
Stevens & Lee 
[Guidance Overview] Oct. 27, 2023 "Plans and issuers subject to these gag clause prohibitions are required to submit an annual attestation here, with the first due Dec. 31, 2023, and on each Dec. 31 thereafter.... The FAQ sheet ... includes helpful examples of what constitutes a gag clause. One such example ... makes clear that a provision giving a TPA discretion over the plan's access is considered a gag clause[.]" MORE >> |
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