Gag Clause Prohibition Compliance Attestation Services
Plans must submit an attestation of their compliance with the prohibition annually by year's end, with the first GCPCAs due by December 31, 2023.
Attestations apply to the period from December 27, 2020 through the date the attestation is made.
WHERE DID THE GCPCA COME FROM?
A Gag Clause Prohibition Compliance Attestation (GCPCA) is an attestation of compliance with Internal Revenue Code (Code) section 9824, Employee Retirement Income Security Act (ERISA) section 724, and Public Health Service (PHS) Act section 2799A-9, as added by section 201 of Title II (Transparency) of Division BB of the CAA, as applicable.