healthcare
There is a new annual compliance requirement that applies to “plans” and “issuers.” For the avoidance of doubt, the term plan means employer and the term issuer means health insurance carrier.
Each year, employers and health insurance carriers must submit a gag clause prohibition compliance attestation. This will be due by December 31st of each year with the first attestation due by December 31, 2023. So, what does this really mean?
- Prior to April 1, 2017, may be issued for longer periods of time so long as the length of coverage does not extend beyond December 31, 2017.
- On or after April 1, 2017, must be limited in duration to periods of less than three months, and that duration includes any renewed coverage.