Lumelight Gag Clause Compliance

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.

Tell us about yourself
Your Name

First NameLast Name
Your Email
example@example.com
Your Phone Number
Please enter a valid phone number.Format: (000) 000-0000.
Tell us about the company that will be using Lumelight Gag Clause Compliance Service to submit their Gag Clause Prohibition Compliance Attestation (GCPCA) to CMS
Employer Legal Name
What is my "employer legal name"?
Employer EIN
(must be in format xx-xxxxxxx)
Employer Business Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Employer Plan Type
ERISA Plan Number
The three-digit Plan Number that is included on the plan's Form 5500. If the plan is not required to file a Form 5500, enter 000.
Attestation Information
Which reporting year are you completing an attestation for?
If you wish to attest for multiple years, please complete this form separately for each year.
What is a reporting year?
Are you attesting to the entire calendar year period?
Should I attest to the entire calendar year?
You have indicated you are not attesting for the entire calendar year, what is the start and end date you wish to attest to?
Start Date

MonthDayYear
2 digit month, 2 digit day, 4 digit yearDate
End Date

MonthDayYear
2 digit month, 2 digit day, 4 digit yearDate
Will you be attesting to all vendor agreements for the plan?
Can I attest to some vendors and not all?
Please check the vendors you plan to attest to their agreements

Other
How many vendors will you be notifying for compliance purposes?
How do I determine the number of vendors for my plan?
Please provide us with the information to notify your plan vendors
Vendor 1
Vendor 1 Company Name
Vendor 1 Attention To
Vendor 1 Mailing Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Where can I find my vendors' addresses?
Vendor 2
Vendor 2 Company Name
Vendor 2 Attention To
Vendor 2 Mailing Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Vendor 3
Vendor 3 Company Name
Vendor 3 Attention To
Vendor 3 Mailing Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Vendor 4
Vendor 4 Company Name
Vendor 4 Attention To
Vendor 4 Mailing Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Vendor 5
Vendor 5 Company Name
Vendor 5 Attention To
Vendor 5 Mailing Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Vendor 6
Vendor 6 Company Name
Vendor 6 Attention To
Vendor 6 Mailing Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Vendor 7
Vendor 7 Company Name
Vendor 7 Attention To
Vendor 7 Mailing Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Vendor 8
Vendor 8 Company Name
Vendor 8 Attention To
Vendor 8 Mailing Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Vendor 9
Vendor 9 Company Name
Vendor 9 Attention To
Vendor 9 Mailing Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Vendor 10
Vendor 10 Company Name
Vendor 10 Attention To
Vendor 10 Mailing Address

Street Address

Street Address Line 2

CityState / Province

Postal / Zip Code
Who should we contact for additional information?
Is this the same individual identified above?
Name

First NameLast Name
Email
example@example.com
Phone Number
Please enter a valid phone number.Format: (000) 000-0000.
If you have a referral code, please enter it here:
Service Summary
Included Deliverables

Compliance Holdings LLC d/b/a Lumelight (“Lumelight”) will provide the Plan Sponsor (“Client”) the following services and deliverables (“Services”):
- Collect necessary information to notify Client’s identified vendors of the prohibitions under the CAA21 within their service agreements on behalf of Client’s plan.
- Collect necessary information to complete and sign on behalf of Client for the Gag Clause Prohibition Compliance Attestation (the “Attestation”) for the attestation year indicated.
- Except as otherwise provided below, timely submit the Attestation through the CMS HIOS system on Client’s behalf for the attestation year indicated.
- Provide Client with a filing confirmation.
Client Responsibilities

Client understands and accepts the following:
- If Lumelight does not receive Client’s necessary information at least 21 business days before the applicable attestation year’s deadline, Lumelight will not complete the Attestation on Client’s behalf when information is received, but does not guarantee timely submission, nor does Lumelight accept any responsibility or liability for penalties related to failure to timely file.
- If Client has failed to file an attestation for a prior attestation year by the applicable statutory deadline, Lumelight will file the attestation on Client’s behalf when information is received and Lumelight has had reasonable time to process the request. Lumelight does not accept any responsibility or liability for penalties related to failure to timely file.
Attestor Designation and Timing:
- Client acknowledges and understands that Client authorizes and assigns Lumelight as the Attestor to complete and electronically sign the Gag Clause Prohibition Compliance Attestation (GCPCA) on behalf of the Client’s responsible reporting entity. Client’s undersigned point of contact further acknowledges they have the authority to delegate such assignment to Lumelight for the sole purpose of completing the described service.
- Client acknowledges and understands that any applicable agreements Client enters into after the attestation end date submitted by Client to Lumelight will be the sole responsibility of Client to include in subsequent Gag Clause Prohibition Compliance Attestations (GCPCAs). Client further acknowledges it is not Lumelight’s responsibility to ensure Client has provided accurate and complete data in relation to applicable CAA21 compliance agreements.
Period of Performance:
- The services listed above will commence on the date Lumelight receives the service request from Client and will continue through the date of completion.
The Services provided by Lumelight are governed by the Lumelight Service Terms (version MST-2026-01) available at:

https://lumelight.com/terms/master-service-terms

To the extent the Services involve Protected Health Information (“PHI”) subject to HIPAA, Lumelight’s HIPAA Addendum (version HIPAA-2026-01) available at:

https://lumelight.com/terms/hipaa-addendum
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Tell us about yourself

Tell us about the company that will be using Lumelight Gag Clause Compliance Service to submit their Gag Clause Prohibition Compliance Attestation (GCPCA) to CMS

Attestation Information

Please provide us with the information to notify your plan vendors

Vendor 1

Vendor 2

Vendor 3

Vendor 4

Vendor 5

Vendor 6

Vendor 7

Vendor 8

Vendor 9

Vendor 10

Who should we contact for additional information?

Service Summary

Included Deliverables

Client Responsibilities

Attestor Designation and Timing:

Period of Performance:

Total Due

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