As part of our ongoing support for the Consolidated Appropriations Act (CAA) gag clause attestation, Excellus BlueCross BlueShield (BCBS) will continue to attest on behalf of our fully insured and minimum premium groups in 2025, unless the group instructs us otherwise.
For Self-funded, Rx carve-out, and Article 47 groups, we have provided a Certificate of Compliance, enabling them to submit their attestation directly to the Centers for Medicare and Medicaid Services (CMS).
Key details for 2025:
- To complete the attestation for our fully insured and minimum premium groups, we must obtain authorization from each group. Renewal forms have been updated for this purpose.
- Fully insured and minimum premium groups that submitted renewal forms in 2025 before the language updates (as mentioned in Updated Fully Insured And Minimum Premium Documentation For 2025 CAA Gag Clause Attestation) will receive a separate letter in the coming weeks. This letter will confirm that Excellus BCBS will attest on their behalf unless they decide to opt out.
- If a group chooses to opt out of our CMS submission, they must notify their account manager by December 1, 2025.
Please note, if a group terminated in 2025, we will not be filing on their behalf for the 2025 gag clause attestation. We will send a certificate of compliance to the group upon request so that they can file the gag clause attestation directly to CMS.
If you or your groups have any questions on the 2025 gag clause attestation or separate letter, please reach out to your account manager for assistance.
