This checklist is designed to help brokers and employers who sponsor group health plans review compliance with key provision of the Affordable Care Act (ACA) and the Consolidated Appropriations Act of 2021 (CAA). If you have any questions, please contact

Note: This list is for general reference purposes only and is not all-inclusive. The information is subject to change based on new requirements or amendments to the law. Additionally, your client’s group health plan may be exempt from certain requirements and/or subject to more stringent rules under your state’s laws.

Employers with fully insured plans will rely on their insurance carrier to submit the report but should confirm this with the insurance carrier. Self-insured employers (including level funded plans) should confirm with their third-party administrator (TPA) or pharmacy benefit manager (PBM) that they will complete the report on the plan’s behalf.

Employers can enter into a written agreement with the insurance carrier or TPA to provide that they will comply with the TiC requirements.

An employer is an ALE in the current year if it employed on average at least 50 full-time employees (including full-time equivalent employees) on business days during the preceding calendar year.

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