"[T]he phrasing of the gag clause prohibition places the responsibility to avoid gag clauses on the plan, rather than the service provide ... [S]ome service providers have already refused to submit the GCPCA on a plan's behalf, and [a legislative fix passed by the House] must still go through both the Senate and the President, meaning it is exceptionally unlikely that [an alternative] will be available to plan administrators prior to the December 31, 2023 GCPCA due date."  MORE >>