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Beyond Attestation: What Employers Need to Know About Gag Clause Prohibition
Sequoia 
[Guidance Overview] Dec. 21, 2025 "The prohibition of gag clauses is more than an annual attestation; it requires active oversight of all plan-related contracts.... [E]mployers should: [1] Audit contracts with TPAs, PBMs, and carriers ... [2] Verify downstream compliance ... [3] Document efforts to remove any prohibited clauses ... [4] Submit your attestation on time if your carrier or TPA does not handle it on your behalf." MORE >> |
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