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Benefit Plan Sponsors › Gag Clauses › Consolidated Appropriations Act (CAA)

Bass, Berry & Sims PLC

Welfare Plan Class Action Litigation Underscores Importance of Minding Your Fiduciary Duties

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As mentioned in our recent blog post, the recently filed class action lawsuit against Johnson & Johnson (Lewandowski v. Johnson & Johnson et. al., D.N.J., No. 1:24-cv-00671 (Feb. 5, 2024)) over alleged excessive prescription...more

Baker Donelson

Surprise! Gag Clause Attestation Due by 12/31/2023

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As part of the No Surprises progeny of legislation seeking transparency in health care, the Consolidated Appropriations Act of 2021 prohibits the use of "gag clauses" in group health plan agreements. All group health plans...more

Bass, Berry & Sims PLC

Let the Plan Speak: First Gag Clause Attestation Due December 31, 2023

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By December 31, 2023, group health plans and health insurance issuers must submit an attestation to certify compliance with the “gag clause prohibition” under the Consolidated Appropriations Act of 2021 (CAA)....more

Holland & Hart - The Benefits Dial

The Time Has Come, A Fact’s A Fact: Consider Adding a Welfare Plan Committee

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The time may have come to add a welfare plan committee to your company’s governance of employee benefit plans. New legal obligations and other developments impose fiduciary risks for welfare plans similar to what already...more

Bradley Arant Boult Cummings LLP

Making the First “Gag Clause” Attestations: A Quick Reference Guide

Bradley Arant Boult Cummings LLP on

Under the Consolidated Appropriation Act of 2021 (CAA), group health plans and health insurance issuers are prohibited from entering into agreements with service providers restricting certain information that the plan may...more

Verrill

Gag Clauses – New Guidance and Litigation Will Inform Compliance

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Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more

Locke Lord LLP

Get Ready to Attest: The Departments ‎Release “Further ‎‎Guidance” on Gag Clause Prohibitions

Locke Lord LLP on

On February 23, 2023, the Departments of Labor, Health and Human Services, and Treasury(collectively the “Departments”) released guidance to initiate the enforcement provisions related to the “gag clause” prohibitions...more

Woodruff Sawyer

Agencies Release FAQs in Advance of the Upcoming Gag Clause Attestation Filing Deadline

Woodruff Sawyer on

When the Consolidated Appropriations Act, 2021 (the “CAA”) was enacted on December 27, 2020, it included a provision that prohibits group health plans and health insurance carriers from entering into certain agreements that,...more

Ballard Spahr LLP

Prohibition Against Gag Clauses

Ballard Spahr LLP on

Summary - Health plan vendors sometimes impose contractual restrictions on the disclosure of data that they consider to be confidential or proprietary. A number of new rules aim to foster transparency and require...more

Fisher Phillips

Overview Of Employee Benefit Provisions In The Consolidated Appropriations Act

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The Consolidated Appropriation Act of 2021 was signed into law on December 27, 2020 and is an impressive 5,593 pages. According to the Senate Historical Office, the Act is the longest bill ever passed by Congress. Buried...more

Faegre Drinker Biddle & Reath LLP

FSA Relief and Significant New Health Plan Requirements Included in Consolidated Appropriations Act of 2021

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The Consolidated Appropriations Act of 2021 (Act), enacted on December 27, 2020, contains a number of provisions that may impact the design and administration of employer-sponsored group health plans and flexible spending...more

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