Seyfarth Synopsis: The Consolidated Appropriations Act, 2021 (“CAA”) contains a requirement that that group health plans may not have agreements with service providers that would restrict certain information that the plan may make available to another party (the “Gag Clause Prohibition”) and must attest on an annual basis that they are complying (the “Compliance Attestation”).
Seyfarth Synopsis: Recent changes to the federal rules governing confidentiality of substance use disorder (SUD) patient records may require updates to agreements between group health plans and their third-party vendors. Group health plans may be caught up in the changes if they wind up in possession of certain SUD patient records and disclose those records