Just as group health plan sponsors finished completing their Consolidated Appropriations Act of 2021 (CAA) prescription and healthcare reporting (referred to as RxDC reporting) for the 2020 and 2021 plan years on January 31, 2023, the June 1, 2023 deadline to submit RxDC reporting for the 2022 plan year is fast approaching.
Many group health plan sponsors relied on their reporting entity vendors, such as plan carriers, third-party administrators (TPAs) and/or pharmacy benefit managers (PBMs), to submit the required RxDC reporting data to the Centers for Medicare & Medicaid Services (CMS) for their 2020 and 2021 plan years. Group health plan sponsors should continue this approach for their 2022 plan year reporting as the June 1, 2023 deadline approaches.
RxDC Reporting Background
The CAA, passed by Congress in December 2020, included a requirement for group health plans (and health insurers) to submit detailed prescription drug pricing and healthcare spending data to CMS.[1] This data, referred to as the RxDC reporting, is collected and aggregated by CMS to publish public reports on prescription drug pricing trends starting this year. Click here for a prior Risk Strategies article with more details.
The federal agencies released an FAQs document in late December 2022 providing a deadline extension (until January 31, 2023) as well as technical clarifications and flexibilities for RxDC reporting requirements for the 2020 and 2021 plan years. However, CMS will likely not grant an extension again for the upcoming June 1, 2023 deadline and will likely not grant additional good-faith relief for 2022 plan year reporting.
Next Steps for Employers
As the June 1, 2023 deadline approaches for the 2022 RxDC reporting, many reporting entity vendors have already reached out to plan sponsor employers with requests for additional information.
These requests generally require employers to report the following information to their reporting entity vendors:
- Plan name (P2 file)
- EIN of Plan Sponsor (P2 file)
- ERISA Plan Number reported on applicable Form 5500 (P2 file)
- Premium Amounts (D1 file):
- Fully insured plans: Dollar or percentage amounts contributed by employees and employers for total aggregated premiums for all plans offered by the same carrier.
- Self-funded plans: Premium equivalent rates including claims cost, administrative costs, TPA fees, and stop-loss premiums OR COBRA premium rates (minus the 2% administration charge).
- Total member count for 2022 plan year (D1 file):
- Members include all employees and their covered dependents.
Employers are advised to take note of the June 1, 2023 reporting deadline and promptly respond to vendor requests with this additional information to ensure timely completion and submission of their 2022 RxDC reporting.
Employers whose vendors will not submit all of the required RxDC reporting data on their behalf will have to register directly through the CMS reporting module called Health Insurance Oversight System (HIOS) to submit the required data. Instructions on how to create an account in the HIOS module can be accessed here. Click here for CMS-issued guidance and resource materials with detailed information on the RxDC reporting process. Since the HIOS registration process can take some time, employers who must report data directly to CMS are advised to begin the HIOS registration process as soon as possible to avoid unnecessary reporting delays and issues.
Risk Strategies is committed to keeping employers informed. Reach out to your Risk Strategies representative with any questions or contact us directly at benefits@risk-strategies.com.
[1] CMS is working on behalf of the Department of Health and Human Services (HHS), the Department of Labor (DOL), and the Department of the Treasury (collectively, federal agencies) with respect to this data collection effort in accordance with the CAA.
