Hunton Employment & Labor Perspectives

The Consolidated Appropriations Act of 2021 (the CAA) requires group health plans and health insurance carriers to attest on an annual basis that they are in compliance with the CAA’s gag clause prohibition. While the prohibition of gag clauses was effective December 27, 2020, the first annual attestation is due December 31, 2023. Group health plan sponsors should begin taking steps now to prepare.

Despite the on-going litigation and Republican opposition in Congress, the Administration continues to work on implementing the Patient Protection and Affordability Care Act of 2010, as amended (the “Act”). Set out below is a brief review of the following important developments from the past 12 months.

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Set out below is a chart that describes the various notices that are required under government regulations for the group health plan reforms and related requirements that will be in going into effect for plan years beginning on or after September 23, 2010 (e.g., January 1, 2011 for calendar year plans) -- including the special notice requirement for those plans that intend to continue to maintain “grandfathered” status, along with a link to any model notice/language provided by the government.

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On July 19, 2010, the United States Departments of Health and Human Services, Labor and Treasury issued interim final regulations covering the mandates under the Patient Protection and Affordable Care Act, as amended (the “Health Care Reform Act”), relating to the internal and external claims review process. These requirements, which do not apply to grandfathered group health plans, substantially expand the claims review and appeals processes that group health plans must follow in administering claims. Because the new requirements apply as of the beginning of the first ...