The world of health insurance continually undergoes regulatory and legislative shifts. A recent change is the mandate surrounding the Gag Clause Prohibition Compliance Attestation (GCPCA), and there’s a lot to unpack. Here’s what you need to know to navigate this regulatory landscape.

Background on the Gag Clause Prohibition Compliance Attestation

Earlier this year, we highlighted the introduction of the Gag Clause Prohibition Compliance Attestation, a result of the 2021 Consolidated Appropriations Act (CAA 2021). In essence, this act mandates certain health insurance issuers and self-funded group health plans to submit an annual GCPCA, reinforcing transparency and rights.

Who’s Affected?

• Fully Insured Customers: If you’re a fully insured customer, breathe a sigh of relief. Horizon will handle the attestation for you as mandated.
• Self-Funded (ASO) Group Health Plans: Groups falling under this category must be proactive. Horizon is stepping up to aid by offering a Certificate of Compliance. This certificate aims to streamline the process for ASO groups, helping them complete their attestations in time.

Prime Therapeutics Joins the Effort

Horizon has joined forces with Prime Therapeutics, our Pharmacy Benefits Manager. In line with our collaboration, we’re disseminating Prime’s Certificate of Compliance. This added layer ensures a comprehensive approach to maintaining regulatory standards across the board.

Key Dates to Remember

December 31, 2023: This date is pivotal. ASO group health plans must ensure they’ve completed and submitted their initial attestation by this date. It’s worth noting that this initial attestation will cover the span starting from December 27, 2020, up to the actual attestation date.

For subsequent years, a recurring annual submission is essential. Each submission will encapsulate the period since the previous attestation and should reach the respective authorities by December 31st of that year.

In Conclusion

Navigating the intricacies of health insurance regulations can be daunting, but it’s crucial to ensure compliance, especially with mandates as significant as the Gag Clause Prohibition Compliance Attestation. By staying informed and leveraging the resources provided by partners like Horizon, organizations can ensure they remain on the right side of the law while also safeguarding the rights and interests of their members.

Stay proactive, stay informed, and let’s journey together in this ever-evolving landscape of health insurance.