December 27 Due Date for Prescription Drug Cost Reporting is Approaching

Posted: November 7, 2022 in CMS , Consolidated Appropriations Act, 2021 , Prescription Drugs / Rx

As part of the Consolidated Appropriations Act of 2021 (CAA), group health plans and carriers will soon be required to report certain demographic and spending information about a plan’s prescription drug expenditures. The Departments will use this data to publish public reports on prescription drug reimbursements, pricing trends, and the impact of prescription drug costs on premium costs. The pharmacy reporting requirement generally applies to group health plans (both fully insured and self-insured) and carriers.

The Centers for Medicare and Medicaid Service (CMS) released several FAQs that clarify requirements under the CAA for prescription drug reporting.

Which wellness services should I include in the RxDC report? (published 8/25/2022)
Do the RxDC reporting requirements apply to limited-scope dental or limited-scope vision plans? (published 8/25/2022)
Will there be training for RxDC? (published 8/25/2022)
Where can I find the updated RxDC reporting instructions that were published on June 30, 2022? (published 8/25/2022)
When can I submit my data in the Health Insurance Oversight System (HIOS)? (published 8/25/2022)
How should I handle vaccines for RxDC reporting purposes? (published 9/1/2022)
Does a group health plan need a HIOS Issuer ID or a HIOS Plan ID for RxDC Reporting? (published 9/1/2022)
I am a vendor submitting the RxDC report on behalf of a group health plan. Does the group health plan need to be registered in HIOS? (published 9/1/2022)
I am a vendor submitting the RxDC report for multiple clients. Can I create multiple submissions in the RxDC HIOS module? (published 9/1/2022)
May multiple reporting entities submit different data file types (D1 - D8) for the same plan or issuer? (published 9/23/2022)
When multiple reporting entities submit data files for the same plan or issuer, does each reporting entity need to submit a plan list (P1, P2, and/or P3)? (published 9/23/2022)
When multiple reporting entities submit data files for the same plan or issuer, does each reporting entity need to fill out every field in the plan list? (published 9/23/2022)
May multiple reporting entities submit the same data file type for the same plan or issuer? (published 9/23/2022)
How do I determine the top 50 drugs with the greatest increase in spending in D5 for a client if the client had a different reporting entity in the previous reference year? (revised 10/4/2022)
How do I calculate restated prior year rebates, fees, and other remuneration in data files D6 - D8 for a client if the client had a different reporting entity in a previous reference year? (published 9/23/2022)

Employer Action Items

Group health plans and carriers are required to submit their first pharmacy report by December 27, 2022 (for calendar years 2020 and 2021) and will need the assistance of their carriers, TPAs, PBMs, or other similar vendors. Fully insured groups should confirm with their carriers that they will comply with this requirement and obtain this in a written document. Self-insured groups should identify and contract with their TPA or PBM to fulfill this requirement on the plan’s behalf.

_{SOURCE: United Benefit Advisors (UBA) and Fisher Phillips, Atlanta}