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Regulations recently promulgated under the Affordable Care Act (ACA) and statutory requirements enacted under the Consolidated Appropriations Act of 2021 (CAA) both include new transparency requirements applicable to group health plans. Unfortunately, however, there is substantial overlap and inconsistency among those twin transparency rules, creating confusion among plan sponsors and health care providers. 

Recent guidance issued by the Departments of Labor, Treasury, and Health and Human Services attempts to resolve that confusion.

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