The Consolidated Appropriations Act requires self-insured plan sponsors to submit a Gag Clause Prohibition Compliance Attestation (GCPCA) to CMS through the HIOS system. The attestation must be submitted by December 31, 2026.
However, Diversified Group will submit the attestations to CMS on behalf of our eligible clients to meet the filing deadline.
Diversified Group will only submit attestations for our self-funded medical clients that were active with Diversified Group during the 2026 reporting year. This includes the client’s medical and pharmacy benefits administered through Diversified Group.
Diversified Group will not submit attestations for any benefits or contracts outside of our relationship with the client. Fully insured plans should check with their insurance carrier to determine whether the carrier will submit the attestation on their behalf.
Per CMS FAQs, Diversified will be submitting the attestations in bulk and not individually.
Client Authorization:
A self-funded plan sponsor may contract with a service provider (such as a TPA) who may submit the attestation on the plan sponsor’s behalf. However, the plan sponsor remains legally responsible for compliance. Self-funded plan sponsors who intend to delegate reporting responsibilities to a service provider should ensure the delegation is stated in a written agreement.
As part of the 2026 submission process, Diversified Group will be sending a data gathering consent form to plan sponsors via DocuSign for completion and signature. This form is intended to establish reporting entity contact details and operates as authorization for Diversified Group to submit the attestation on the plan sponsors behalf.
Please complete the DocuSign form when received. Be sure to complete all required fields, check the authorization box, and sign and date the form.
Please note that any required data or consent not received by Diversified Group will not be included in this year’s submission.
If you have any questions, please feel free to contact our compliance team at dgcompliance@diversifiedgb.com or by visiting our website.
Leave A Comment