The Lumelight Gag Clause Compliance Service will notify identified plan vendors of the plan’s intention to consider any gag clauses found in their service agreements to be unenforceable as applicable under the Consolidated Appropriations Act, 2021 (CAA21) and complete the attestation requirements on behalf of the group health plan sponsor. Under the CAA21 group health plans are prohibited from entering into any agreements containing gag clauses, as defined by the rule, and must attest to their compliance, annually, through CMS’s HIOS system. The registration deadline to ensure timely filing and notification to vendors is December 9th each calendar year. After completing the signup form and accepting the Lumelight Gag Clause Compliance Service Terms & Conditions, you will be sent a copy of the information submitted. After receipt of your sign-up information, Lumelight will send your identified plan vendors compliance letter(s) on behalf of the plan and, following a 15-day delivery period, will file the plan’s attestation to CMS. Finally, you will receive a receipt of filing once CMS has accepted our submission on your behalf.
Our compliance specialists will be available to answer questions throughout the Gag Clause compliance information collection process via email at gagclause@lumelight.com.
To sign up for Lumelight Gag Clause Compliance Service, please complete the form on the next page. Click Here for more in-depth information regarding Gag Clause Compliance under the CAA21. This service is priced based on the number of vendors the plan intends to notify regarding the compliance of your service agreements and is priced as follows:
| Up to 3 vendors: |
$500 |
| Additional vendors: |
$100 each |
*Please note that for purposes of this filing requirement a “plan” is considered the legal entity sponsored by an employer (or in certain cases an association, trust, committee, etc.), not a plan option. In most cases, each employer sponsors a single plan for their employees. Where this is not the case, the employer or plan sponsor is generally aware that they sponsor more than one legal plan. If you have questions about how many plans you sponsor and/or how many vendors are applicable to this compliance requirement, please contact us at gagclause@lumelight.com.