On December 23, 2022, federal agencies (the Departments of Labor, Health and Human Services, and the Treasury, collectively) released an FAQs document extending the reporting deadline for the Consolidated Appropriations Act, 2021 (CAA) prescription and healthcare spending data (referred to as RxDC reporting) from December 27, 2022, to January 31, 2023.
This deadline extension provides welcome relief for group health plans who have not yet submitted their RxDC reporting data to the Centers for Medicare & Medicaid Services (CMS), particularly those employers who must submit all or some of the RxDC reporting files directly to CMS on behalf of their group health plan. Note that many insurance carriers, third-party administrators (TPAs), and/or pharmacy benefit managers (PBMs), considered “reporting entities,” have already confirmed they submitted the RxDC reporting data on behalf of their group health plan clients.
Acknowledging the significant operational challenges that reporting entities have encountered in their compliance efforts with these new and complex reporting requirements, the agencies also confirmed in the FAQs they will not take enforcement action against any plans using a good faith, reasonable interpretation of the regulations and reporting instructions when submitting their RxDC reporting data to CMS.
The FAQs also contained several technical clarifications and flexibilities regarding the reporting requirements, including the following:
- Submissions by multiple reporting entities on behalf of the same plan
- More than one reporting entity may submit the same data file type on behalf of the same plan, instead of working together to consolidate all of the plan’s data into a single data file for each type of data.
- Flexibility for certain limited data to be reported via email, rather than submitted in the RxDC reporting module (called HIOS).
- The email address to submit the limited data file (only the plan list, premium and life-years data, and narrative response) is RxDCsubmissions@cms.hhs.gov. The submission may include optional supplemental documents. The name of each file should include the reference year of the submission, the plan list or data file type (e.g. P2, D1), and the name of the group health plan sponsor.
- Optional reporting on vaccines
- Optional reporting of amounts not applied to the deductible or out-of-pocket maximum
- A reporting entity may leave the data fields in these columns blank from data files D2 and D6, but reporting entities should not remove the columns themselves.
- Multiple submissions by the same reporting entities
- Suspension of data aggregation requirements
These technical clarifications primarily impact reporting entities, rather than employers sponsoring group health plans. However, those employers responsible for submitting their RxDC reporting directly to CMS are advised to take note of the items listed above.
Click here for a previous Risk Strategies article with background information and more details on RxDC reporting requirements.
This last-minute RxDC reporting deadline extension to January 31, 2023, will serve as a welcome respite for those group health plans who have yet to submit their RxDC reporting data to CMS.
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