Compliance Without 
The Complexity

We have RxDC reporting requirements on our minds these days. Specifically, we’ve been worried about our employer friends and how they will handle P2 and D1 filings.

In May of this year, the Internal Revenue Service and the Departments of Labor and Health and Human Services released updated versions of the Submission Instructions and User Manual for the Gag Clause Prohibition Compliance Attestations (GCPCAs) due by the end of 2024. This update includes several notable changes to the annual submission process for group health plans and issuers offering group or individual health insurance coverage.

As many of you know, the Department of Labor (DOL) released their much-anticipated Mental Health Parity and Addiction Equity Act (MHPAEA) Final Rules last month. Many of the more significant updates to the requirements don’t take effect until a plan’s renewal on/after January 1, 2026, but a few notable items will begin applying in just a few months, once a plan renews on/after January 1, 2025. These provisions include a new fiduciary certification, a codified termination of the MHPAEA opt-out opportunity for non-Federal governmental plans, and both new and revised definitions for relevant terms.

In an effort to make sure patients are provided with accurate information concerning prices of their healthcare, the President has issued an Executive Order directing further enforcement of the Executive Order he signed in 2019 (EO 13877).