Health Net: GCPA Confirmation for Large and Small Groups

The Consolidated Appropriations Act, 2021 (CAA) includes an annual attestation requirement for plans to certify their compliance with the gag clause prohibition.  This is referred to as the annual Gag Clause Prohibition Compliance Attestation, or “GCPCA”.

The gag clause prohibition in the CAA prohibits health plans from entering contracts that restrict specific data and information that a plan can make available to another party.  Plans must annually submit an attestation that they have not entered any prohibited contractual restrictions.

Health Net of California, Inc. (Health Net) attested to the 2025 Gag Clause Prohibition Compliance on December 19, 2025, directly on behalf of its fully insured groups to the Departments of Labor, Health and Human Services, and the Treasury. Health Net will continue to monitor applicable regulatory guidance and requirements related to the gag clause prohibition and will address future attestation obligations in accordance with federal requirements. 

2025 Submission Reference Number: 102746.