RxDC Reporting for 2023

Get ready for the next round of prescription drug data collection (RxDC) reporting! Annual reporting is required by June 1 of each year. Calendar year 2023 data reporting is due June 1, 2024. Most employers sponsoring group health plans that provide prescription drug coverage, regardless of size or funding (fully insured or self-funded), have some role to play in the RxDC process. We are already seeing communications and notices from vendors requesting information to begin preparing for the reporting over the next couple of months, so below is a refresher on the RxDC reporting requirements and responsibilities.

Background

In accordance with the Consolidated Appropriations Act, 2021 (CAA), health plans, including grandfathered plans, and health insurance carriers are required to submit certain information about prescription drug and health care spending to the agencies annually. The agencies plan to use this information to issue public reports on prescription drug pricing costs and trends.

RxDC reporting requirements apply to group health plans, but not account-based plans such as health reimbursement arrangements (HRAs) or excepted benefits (e.g., limited-scope dental or vision, onsite clinics, and many employee assistance programs (EAPs).

Reporting Responsibilities

The responsibility for the reporting officially lies with the employer plan sponsor. For fully insured plans, the insurer can be solely responsible for the reporting obligation as long as the plan sponsor and insurer execute a written agreement requiring the insurer to be responsible. Plan sponsors of self-insured or level-funded plans may have a third-party, such as a third-party administrator (TPA), or pharmacy benefit manager (PBM) submit some, or all, of the data on their behalf.

How carriers, TPAs, PBMs and other vendors of prescription drug coverage handle the RxDC reporting varies greatly.

• The carrier or TPA may reach out to plan sponsors requesting specific plan information necessary to complete the P2 Plan List and/or D1 Data File. For employers that offer a fully insured plan where all prescription drug coverage is handled by the carrier, once this information is provided to the carrier, the carrier will generally handle the RxDC reporting. However, if the employer fails to timely respond, the employer may have to file a P2 and D1 file for the group health plan.
• A few carriers and TPAs will file only fields D2-D8, but not the D1, in which case the employer is responsible for submitting the P2 and D1 files on its own.
• For employers using vendors that will not handle the RxDC reporting (only help provide data), or for employers that use multiple unrelated vendors to provide prescription drugs coverage (e.g., separate TPAs and PBMs, or carve-out drug coverage or stand-alone telehealth), the employer may have to take a more significant role in determining which vendors are reporting which files, and perhaps even consolidating information and submitting more of the files itself.

Next Steps

ALL plan sponsors, fully insured and self-insured, should watch for communications from their vendors (carrier, TPA and/or PBM) to determine how much of the reporting will be done by the vendor, and what, if anything, the employer needs to do to complete the process. If you have not yet heard from your vendor(s) – reach out to them directly or contact your AssuredPartners team for assistance!

If your Carrier, TPA and/or PBM is reporting on your behalf, make sure you comply with their specific deadline(s) for providing any requested information. Most reporting entities have already contacted plan sponsors with requests for specific information necessary to file on the plan sponsor’s behalf. These requests have strict deadlines with which plan sponsors must comply to ensure the reporting entity files on its behalf in a timely manner. Some vendors have deadlines as early as March 1st!

If you must report some, or all, of your health plan’s information you must do so through HIOS. Each submitting organization will be required to have at least two (or more) individuals with an active HIOS account. If you do not already have a HIOS account, you will first need to obtain your Identity Management System (IDM) credentials. The credentials are obtained by completing registration through the IDM secure authentication process. It may take up to TWO WEEKS to obtain credentials!

Detailed reporting instructions, including templates for the various data files and other important information, can be found on the CMS RxDC website.

Should you have any questions or need additional information, please contact a member of your AssuredPartners Employee Benefits Team.

Please see our previous guidance outlining the RxDC Reporting Mandate here.