As part of the Consolidated Appropriations Act, 2021 (CAA), all insurance companies and self-funded health plans (except HRAs and ICHRAs) must provide de-identified prescription drug and health cost reporting to the federal government.

The primary goal of the reporting is for the federal government to identify prescription drug trends and compile the data into a biannual report (without identifying plans or individuals).

The first RxDC report was due December 27, 2022, and carriers of fully insured plans submitted the report without much fanfare mostly because the regulatory agencies initially allowed a good faith estimate of certain information. For 2022 reporting and beyond, there is no longer an option for a good faith estimate which means carriers will have to collect group health plan specific information for the 2022 report due June 1, 2023.

Why is the reporting important to me?

For fully insured health plans, most carriers are submitting the data on behalf of their customers. Although, some of the data must be provided by the employer.  This means carriers are sending out communication to their customers to gather that information. Employers with group health plans must take action. 

What action is required of employers administering group health plans?

It largely depends on the carrier and the funding arrangement (i.e. self-insured vs. fully insured). In this article, we focus on fully insured group health plans. Carriers are sending out communication via email to collect information necessary to submit a complete RxDC report.

Fully insured group health plans must respond to their carrier by the deadline noted in the email communication.

Each carrier has its own method of gathering the information. For the most part, we’ve seen carriers request data via an online survey or form.

What happens if I miss the deadline?

If the deadline is missed, it’s likely that the group health plan will have to submit their own D1 file required by law. This means the group health plan administrator will need to register with the CMS HIOS system and upload the D1 file.

Note: we don’t want our employers in this position as it creates quite a burden. The way to avoid this extra burden is to respond to the carrier’s request for more information.

What information is being requested?

Each carrier is approaching this a bit differently. In general, carriers are requesting the following information to be completed via an online form:

  • Group Name
  • Group Number
  • Average monthly premium paid by members for 2022
  • Average monthly premium paid by the employer for 2022
  • Form 5500 Plan Number, if applicable

How will this reporting impact group health plans?

While RxDC creates an extra administrative burden, the goal of the new reporting is for agencies to gather information that can be used by the federal government and businesses to eventually lower drug costs.

What are next step for employers?

Employers with fully insured group health plans should act immediately. Carrier deadlines to submit the required information are approaching.

Employers with self-funded group health plans should have already connected with their TPA to complete the reporting due at the end of last year. Please work with your TPA closely again to ensure they submit the information on your plan’s behalf.

For further questions or concerns, please contact your IMA benefits broker. For non-Bolton clients, we suggest connecting with your current benefits broker.

This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.

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