The CAA provision requires an annual gag clause prohibition compliance attestation (GCPCA). The deadline for completion of attestations is December 31, 2023.
As previously announced, UnitedHealthcare will make the attestation for fully insured customers and these customers do not need to take action.
However, level funded/self funded plan administrators will need to take action to submit the attestation. UnitedHealthcare has now released a Confirmation of Compliance to support these customers.
Plan sponsors may use the Confirmation of Compliance to support their attestations for any UnitedHealthcare administered medical, behavioral, and/or pharmacy business.
Special note: if pharmacy coverage is through OptumRx Direct, plan sponsors must attest for that separately. OptumRx sent their attestation to affected customers in March 2023.
Contact your Amwins Connect Regional Sales Manager with questions or for more information.