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The Gag Clause Quandary for Self-Insured Group Health Plans: New FAQ Guidance
Verrill Dana LLP 
[Guidance Overview] Jan. 27, 2025 "Considering the guidance in FAQs Part 69, the best approach for plan sponsors ... may be to carefully record their attempts to eliminate prohibited gag clauses from their ASAs. FAQs Part 69 states that this information can be included in the annual gag clause prohibition compliance attestation, and including the information will, hopefully, provide some protection to the plans until TPAs and others are held to account." MORE >> |
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