Document Your Due Diligence

The Consolidated Appropriations Act of 2021 (CAA) strengthened plan sponsors’ fiduciary duties as the

administrators of their health plans. To boost transparency in health and prescription drug spending, the CAA

issued mandates that directly impact plan sponsors of ERISA-covered group health plans. As plan sponsors,

employers have an obligation to review their plans in light of these requirements to confirm the plan is

operating efficiently and to ensure compliance with the regulations. Plan sponsors may be held directly liable in

an audit or litigation.