Your Health Plan is the Latest Fiduciary Ticking Time Bomb
The Consolidated Appropriations Act of 2021 (CAA) is the most significant compliance challenge employers have faced since the Affordable Care Act. New requirements are in effect now, including:
Required review of plan contracts and removal of all “gag clauses,”
Required determination of “reasonableness” of vendor fees and services,
Required prescription drug reporting for plan years 2020, 2021, and 2022 (due Jan. 21, 2023), and
Required analysis of parity between medical and mental health coverage.
Failing to comply with the requirements of the CAA leaves employers at risk of fines and class-action lawsuits. But most employers are still in the dark,…