Consolidated Appropriations Act
The Consolidated Appropriations Act added several yearly duties for group health plans. Most are easy to meet with a little planning, and easy to miss without it.
New yearly filings, explained and handled before the deadlines.
What does the CAA require?
The Consolidated Appropriations Act (CAA) requires group health plans to file annual prescription drug and health care spending (RxDC) reports by June 1, attest each year by December 31 that their contracts contain no prohibited gag clauses, receive broker and consultant compensation disclosures, and document mental health parity comparisons. It also brought the No Surprises Act's billing protections.
How we help
RxDC reporting
Annual pharmacy and medical spending data due June 1. Insured plans usually rely on the carrier; self-funded plans coordinate with their TPA and PBM.
Gag-clause attestation
An annual attestation, due December 31, that your contracts don't block access to cost and quality data.
Broker compensation disclosure
Written disclosure of the compensation brokers and consultants expect to receive. We provide ours up front.
Mental health parity
Comparative analyses showing limits on mental health benefits are no stricter than on medical benefits.
No Surprises Act
Protections against surprise bills for emergency care and certain out-of-network services.
Price transparency
Machine-readable files and cost-sharing tools, handled by carriers for insured plans.
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Frequently asked questions
Does the CAA apply to fully insured plans?
Yes, but for most requirements the carrier does the heavy lifting. The employer still needs to confirm the carrier is filing RxDC reports and the gag-clause attestation on the plan's behalf.
When is the gag-clause attestation due?
Each year by December 31, covering the period since the last attestation.
What does the broker compensation disclosure include?
The direct and indirect compensation a broker or consultant expects to receive for services to the plan. We share ours with every client.
Schedule a commitment-free meeting
Tell us what's working and what isn't. We'll review your benefits or coverage and give you an honest plan, at no cost.