In August 2021, the Departments of Labor (DOL), Health and Human Services (HHS), and Treasury (the Departments) issued an FAQ addressing certain elements of the CAA provisions. While the industry may believe that certain parts of the legislation have been delayed, the reality is they have not. This legislation is still very much in effect!
What dates were affected and why?
Gag clauses: The requirement to remove gag clauses by the end of 2021 is still in effect. The Departments however, have provided additional clarification regarding the timeframe for plan sponsors to submit their attestations of compliance. The FAQ states that regulators anticipate the collection of attestations to begin in 2022. This clarification does not affect the requirement for plan sponsors to remove any and/or all gag orders by the end of 2021. Despite the delay in attestation, the FAQ makes it clear that plan sponsors are expected to implement the requirements: "Until any further guidance is issued, plans and issuers are expected to implement the requirements prohibiting gag clauses using a good faith, reasonable interpretation of the statute."
Pharmacy reporting:
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