In late 2021, Congress passed the Consolidated Appropriations Act, 2021 (CAA) which contained a provision that requires health care plans to submit Prescription Drug Data Collection (RxDC) reports to CMS.
The new reporting requirement applies to most health insurance issuers and group health plans, including self-funded and grandfathered plans. Account-based plans, such as health reimbursement arrangements, and excepted benefits (e.g., short-term limited-duration, hospital or disease-specific insurance) are exempt.
Unfortunately, accessing this data can be complicated for many plans, and reporting it requires submitting multiple parts (i.e., one or more plan lists (P1-P3), eight data files (D1-D8) and a “narrative response”). As a result, there has been some confusion and stress about what the RxDC will mean for health plans.
Since the RxDC was made retroactive for 2020 but had its implementation delayed for a year, health plans are now required to submit their prescription drug and health care spending data for both the 2020 and 2021 reference years by this year’s deadline of December 27, 2022.
What is the Purpose of the RxDC?
RxDC reporting will provide CMS with aggregated premium and spending information from health plans. The required “narrative response” from a plan will describe to CMS the impact of drug rebates on its premiums and cost sharing. The process of gathering the data will also give health plans a good opportunity to see what their information looks like and whether their spending data matches their expectations.
Who Will the Process Involve?
Data must be submitted via the RxDC module in the Health Insurance Oversight System (HIOS). Health plans can contract with issuers, third-party administrators (TPAs), Pharmacy Benefit Managers (PBMs) or other vendors to submit data on their behalf. Plans can have multiple vendors submit on their behalf (e.g., a TPA and a PBM); however, if a plan has multiple vendors submitting data, the vendors should not submit the same categories of data files. This may take some coordination by the health plan.
Note: For health plan sponsors that will be self-reporting data (because a vendor is not reporting on your plan’s behalf), you will likely need to create a CMS Enterprise Portal and HIOS account. It can take up to two weeks to create your accounts. Don’t wait until the last minute!
Upcoming RxDC Webcast
To help members get a better understanding of issues surrounding the CAA and the RxDC, the International Foundation of Employee Benefit Plans will be hosting the webcast Prescription Drug Data Collection (RxDC)—What You Need to Know About the Required CMS Reports on November 17 at 3:00 p.m. ET. The webcast will feature Dr. Susan Hayes, Mike Miele of Capital Rx and Denis Duffey, who will be looking at the process and opportunities of RxDC from the perspective of plans, PBMs and the legal framework.
CMS’s detailed RxDC reporting document can be found here.
Instructional Designer at the International Foundation
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