Late last year, Congress passed the Consolidated Appropriations Act, 2021 (CAA), which contained a provision requiring health care plans to submit Prescription Drug Data Collection (RxDC) reports to CMS.

RxDC was made retroactive for 2020 but its implementation was delayed for a year; therefore, 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.

Unfortunately, the submission process required by CMS for RxDC has created confusion for many health plans. To help members better understand the issues surrounding the CAA and the RxDC, the International Foundation of Employee Benefit Plans hosted a webcast: Prescription Drug Data Collection (RxDC)—What You Need to Know About the Required CMS Reports. The webcast featured Dr. Susan Hayes, Mike Miele of Capital Rx and Denis Duffey, who looked at the process and opportunities of RxDC from the perspective of plans, PBMs and the legal framework.

Key Takeaways

The webcast covered several important issues facing health plans dealing with RxDC and answered viewer questions. (In fact, about half of the 90-minute webcast was dedicated to Q&A.)

Not all the content can be covered in this article, but here are five of the key takeaways from the webcast:

It’s important to act now
The deadline for RxDC submission is nearing, and the penalties for noncompliance (even good-faith noncompliance) are unknown. It’s important for health plans to start coordinating how their data will get submitted and—if they haven’t yet—set up their CMS account. (It can take up to two weeks to create a HIOS account through the CMS Enterprise Portal.)

Health plans are responsible for what gets submitted
While PBMs can submit data files on behalf of a health plan, the health plan is ultimately responsible for ensuring that the files are accurate and submitted correctly.

Reporting is a new opportunity for plans
Perhaps the most important takeaway was that health plans should look at this as both a responsibility and an opportunity. The data files can effectively show exactly how a PBM is benefiting a health plan and whether it is delivering on its promises. These files can also help a plan better understand its own formulary and identify which drugs are most used by members.

Make sure you can get PBM data
Not all PBMs seem to be excited about sharing data with health plans. Some PBMs are willing to submit data to CMS on behalf of a health plan for free but will charge health plans for copies of their data to submit for themselves. Since the data could be very insightful, a panelist encouraged health plans to find ways ensure that they receive their data—even suggesting that access to it be a condition in their contract with a PBM.

RxDC will bring changes . . . but not overnight
The RxDC reporting seems designed to increase the transparency of drug price determination and to help identify drug utilization rates. While RxDC is expected to succeed in some capacity, it could take a few years of regular reporting before the transparency produces real patterns and accountability.

CMS’s detailed RxDC reporting document can be found here.

Jonas Leyrer
Instructional Designer at the International Foundation

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Jonas Leyrer, CEBS

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