The Consolidated Appropriations Act (CAA) gag clause prohibition requires issuers and plan sponsors to attest that any agreements they enter with health care providers, third-party administrators or other service providers will not contain language restricting access to cost and quality-of-care information. Compliance requires an annual submission of a Gag Clause Prohibition Compliance Attestation (GCPCA) by December 31, 2025, from the plan and/or issuer.
Carriers have varying approaches to completing gag attestations. See below for a list of current carrier stances. Bukaty Companies will continue to monitor carrier announcements and update this page as necessary.
| Issuer/Carrier/TPA | Fully insured | Level-funded / AFA / Split-funded | Self-funded |
| Aetna | No action needed by client | No action needed by client | No action needed by client |
| Blue Cross Blue Shield of Kansas (BCBSKS) | No action needed by client | Client must affirmatively opt in by Nov. 14 for BCBSKS to attest on group’s behalf | Client must affirmatively opt in by Nov. 14 for BCBSKS to attest on group’s behalf |
| Blue Cross Blue Shield of Kansas City (Blue KC) | No action needed by client | Client must attest | Client must attest |
| Cigna | No action needed by client | No action needed by client | Client must attest |
| UHC | No action needed by client | No action needed by client |
Client must attest* *Clients that submitted a request to UHC to complete the attestation on their behalf by November 1 do not need to attest. |
| Gravie | Not applicable | Not applicable | Not applicable |
Plan sponsors responsible for completing the attestation on their own behalf can learn how to complete gag attestations using Bukaty Companies' How-To Guide.
For additional information and support, contact your Bukaty benefits consultant or support team.
