Consolidated Appropriations Act

Information for this crucial part of legislation

There are four areas of the Consolidated Appropriations Act (CAA) that plan sponsors, as fiduciaries must both familiarize themselves and comply with.

Plan sponsors will have to “attest” annually to performing the following functions:

Removal of “Gag Clauses” from service provider contracts. Gag clauses in contracts prohibit an employer from being able to have full transparency and utilize their data as a fiduciary.

Plan sponsors are required to collect from Covered Service Providers disclosures of both “direct and indirect compensation” for amounts over $1,000. In conjunction, plan sponsors are required to collect a list of services associated with direct and indirect compensation. 

Reporting requirements for pharmacy and prescription drug disclosures. Effective July 1, 2022, plan sponsors are required to report certain information to HHS, DOL, and treasury including drug pricing, frequency of drug costs increase, premiums, rebates, and out-of-pocket costs. 

Plan sponsors are to analyze nonquantitative treatment limitations on MH/SA benefits to show parity with medical and surgical care.

Download these PDFs:

CAA Goals

Organizing their priorities

CAA Summary


CAA Toolkit

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