The Consolidated Appropriations Act of 2021 (CAA) is the most significant compliance challenge employers have faced since the Affordable Care Act. Benefit advisers who serve the health and welfare side of our industry no doubt will need to continue paying close attention to this landmark legislation on behalf of their employer clients.
New requirements are now in effect. They include the review of plan contracts and removal of all “gag clauses;” determination of “reasonableness” for vendor fees and services; prescription drug reporting for plan years 2020, 2021 and 2022; and analysis of parity between medical and mental health coverage.
