It would be understandable if some leaders of self-funded benefits plans have not devoted ample time and attention to the Consolidated Appropriations Act (CAA), introduced into law in late 2021. Plan sponsors, including big and small companies, labor unions, and other organizations that provide health benefits, have had their hands full fending off challenges on multiple fronts posed by the pandemic, talent shortages, inflation, and persistent foreboding economic news.

So it wouldn't be shocking to learn that new legislation related to health coverage — typically the domain of HR and benefits managers — might not have risen to the top of their priority list.

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