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December 31 Deadline for Health Plan Gag Clause Attestation

The "No Surprises Act" requires price transparency for certain medical and pharmacy costs and health plans and health insurance policy issuers must make sure that the contracts they enter into allow the sharing of this information. Starting this year plans and issues are required to file an online attestation confirming that they comply. The first attestation is due no later than December 31, 2023, for applicable periods prior to 2024. Starting in 2024, an annual attestation must again be made by December 31. The DOL, HHS, and the Treasury Department just issued new FAQs providing guidance on how plans and issuers can satisfy the attestation requirement, which can be found here:

Contact your Boutwell Fay attorney if you have questions on this topic or email us at


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