Gag Clause Attestation Chart By Carrier

Gag Clause Attestation Carrier Chart and Links to Additional Website Articles

The deadline for submitting the Attestation to CMS is December 31, 2023 and is just around the corner. Below you will find information specific by carrier along with other links to articles that were posted over the past few months. Some of the articles are carrier specific. A few of the articles provide information on the process to submit the attestation.

Gag Clause Attestation - Responsibility by Carrier

Carrier	Carrier Will Submit to CMS	Plan Must Submit to CMS	Notes
Aetna	Fully Insured and Small Group AFA Plans
Allstate - Level Funded *	Allstate Benefits will attest on the Group's behalf.
Anthem	Fully Insured (and Small Group MEWA, ABF, Minimum Premium, and FEHP	ASO Clients; JAA and MCS Clients
Blue Shield of California	Fully Insured and Flex-Funded Groups	Shared Advantage and Shared Advantage Plus	Self-Funded ASO Groups must have submitted intake form to carrier by 10/27/2023 in order for carrier to submit on their behalf.
Cigna Healthcare and Cigna + Oscar	Cigna Healthcare and Cigna Healthcare's Fully Insured Clients	Confirmation letter was provided to Self-Insured/ASO Clients
Empire	Fully Insured Groups	ASO, JAA and MCS Clients
Florida Blue	Will attest for all Groups
Health Net	Fully Insured Groups	Self-Funded medical plans need to consult with TPA to determine which party will complete the Attestation
Kaiser Permanente	Will attest for all Groups
United Healthcare	Fully Insured Groups	Self-Funded and Level Funded Clients
Healthy Advantage - Level Funded (Sisco Benefits) **

Carrier

Carrier Will Submit to CMS

Plan Must Submit to CMS

Notes

Aetna

Fully Insured and Small Group AFA Plans

Allstate - Level Funded *

Allstate Benefits will attest on the Group's behalf.

Anthem

Fully Insured (and Small Group MEWA, ABF, Minimum Premium, and FEHP

ASO Clients; JAA and MCS Clients

Blue Shield of California

Fully Insured and Flex-Funded Groups

Shared Advantage and Shared Advantage Plus

Self-Funded ASO Groups must have submitted intake form to carrier by 10/27/2023 in order for carrier to submit on their behalf.

Cigna Healthcare and Cigna + Oscar

Cigna Healthcare and Cigna Healthcare's Fully Insured Clients

Confirmation letter was provided to Self-Insured/ASO Clients

Empire

Fully Insured Groups

ASO, JAA and MCS Clients

Florida Blue

Will attest for all Groups

Health Net

Fully Insured Groups

Self-Funded medical plans need to consult with TPA to determine which party will complete the Attestation

Kaiser Permanente

Will attest for all Groups

United Healthcare

Fully Insured Groups

Self-Funded and Level Funded Clients

Healthy Advantage - Level Funded (Sisco Benefits) **

* Allstate - Level Funded - Clients received a link prior to the carrier's closing date in order to complete a questionnaire. Clients who did not complete will need to go to the CMS website to complete and submit the Attestation.

** Healthy Advantage - Sisco Benefits will attest on behalf of every client who signs over the responsibility to Sisco. Information was sent to the clients and the broker. The clients were to complete and sign the document in the announcement and return it to Sisco Benefits no later than 11/15/2023. If the client did not meet the deadline, they will need to go to the CMS website to complete and submit the Attestation.

Links to Articles on our website

^{While every effort has been taken in compiling this information to ensure that its contents are totally accurate, neither the publisher nor the author can accept liability for any inaccuracies or changed circumstances of any information herein or for the consequences of any reliance placed upon it. This publication is distributed on the understanding that the publisher is not engaged in rendering legal, accounting, or other professional advice or services. Readers should always seek professional advice before entering into any commitments.}