2025 Gag Clause Prohibition Compliance Attestation Submission

Dec. 17, 2025

(Applies to All Groups*)

The Centers for Medicare & Medicaid Services collects Gag Clause Prohibition Compliance Attestations from applicable group health plans and issuers offering group and individual health insurance coverage. These attestations are due by Dec. 31 each year based on current guidance from the federal government.

Blue Cross and Blue Shield of Texas submitted its GCPCA as a health insurance issuer on Dec. 1, 2025. Our attestation covers the applicable date range of Dec. 1, 2024, to Nov. 30, 2025.

What does this mean?

For Fully Insured plans: BCBSTX's attestation as a health insurance issuer will satisfy the GCPCA requirement for Fully Insured plans. No action is needed from these groups.

For Self-Funded plans: As previously announced, due to the nature of business for these funding types, Self-Funded group customers will need to submit their own GCPCA attestation by Dec. 31, 2025. The prior announcement included BCBSTX’s confirmation of compliance statement, which groups may use to support their own attestation within the CMS portal.

Questions? If you have any questions, please contact your BCBSTX representative or General Agency.

*This article, or a similar version, is being shared with employer groups in our employer newsletter or news alert.