CAA 2026 Employer Compliance Assessment — Free Readiness Scorecard
CAA 2026 Employer Compliance Assessment
Score your health plan across all five CAA compliance pillars: transparency, mental health parity, surprise billing, gag clause attestation, and broker disclosure.
About This Assessment
This assessment is for educational purposes only and does not constitute legal or compliance advice. Results reflect self-reported information. Consult qualified ERISA counsel for a formal compliance review.
The Consolidated Appropriations Act (CAA) has introduced sweeping new compliance obligations for employer-sponsored health plans — from machine-readable file publication and prescription drug data reporting to mental health parity analysis, surprise billing protections, gag clause attestation, and broker compensation disclosure. This free assessment scores your plan across all five CAA compliance pillars so you know exactly where you stand before a regulator or plan participant asks.
5 CAA Pillars
Transparency, MHPAEA, NSA, Gag Clause, Broker Disclosure
15 Questions
Targeted to the highest-risk CAA compliance gaps
Instant Score
Pillar-by-pillar breakdown with priority action items
Free & Confidential
No login required — results stay in your browser
Put fiduciary learning into practice
Check your plan governance.
Evaluate your plan’s CAA transparency, mental health parity, surprise billing, gag-clause, and broker-disclosure readiness.
Run Compliance Assessment
Has your carrier or TPA confirmed that machine-readable files (MRFs) for in-network rates and out-of-network allowed amounts are published and up to date?
Frequently Asked Questions
What is the CAA and why does it matter for employer health plans?
The Consolidated Appropriations Act (CAA) of 2021, along with subsequent guidance through 2026, introduced the most significant employer health plan compliance requirements in a decade. Key provisions include machine-readable file (MRF) publication, prescription drug data collection (RxDC) reporting, enhanced mental health parity (MHPAEA) analysis, No Surprises Act (NSA) protections, gag clause prohibition attestation, and broker/consultant compensation disclosure. Non-compliance can result in excise taxes, DOL audits, and participant lawsuits.
What is the Gag Clause Prohibition Compliance Attestation (GCPCA)?
The GCPCA is an annual attestation that employers must submit to CMS confirming that their contracts with carriers, TPAs, and networks do not contain gag clauses that restrict access to cost and quality data. The attestation is due December 31 each year. Failure to attest can result in excise taxes of $100 per day per affected participant.
What is the RxDC reporting requirement?
The Prescription Drug Data Collection (RxDC) report requires employer-sponsored health plans to submit detailed data on prescription drug spending, rebates, and plan costs to CMS annually. The report covers the prior calendar year and is typically due June 1. Carriers and TPAs often file on behalf of fully-insured plans, but self-funded plan sponsors retain ultimate responsibility for compliance.
What does the No Surprises Act require from employer health plans?
The No Surprises Act (NSA) prohibits surprise billing for emergency services and certain non-emergency services at in-network facilities. Employer plans must ensure EOBs include required cost-sharing disclosures, implement processes for Independent Dispute Resolution (IDR) requests from out-of-network providers, and — once fully effective — send Advanced Explanations of Benefits (AEOBs) before scheduled services.
What is an NQTL analysis and who needs one?
A Non-Quantitative Treatment Limitation (NQTL) analysis is a written comparative analysis documenting that non-quantitative limits on mental health and substance use disorder (MH/SUD) benefits — such as prior authorization, step therapy, and network adequacy standards — are no more restrictive than those applied to medical/surgical benefits. All employer-sponsored group health plans subject to MHPAEA must have an NQTL analysis available for review by regulators or participants upon request.
What broker compensation disclosures are required under the CAA?
CAA Section 202 (codified in ERISA Section 408(b)(2)) requires brokers and consultants who reasonably expect to receive $1,000 or more in direct or indirect compensation in connection with a group health plan to provide written disclosure of all such compensation to the plan fiduciary. Plan fiduciaries must review these disclosures and document that compensation is reasonable for services rendered. Failure to obtain required disclosures is a prohibited transaction under ERISA.
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