The Centers for Medicare and Medicaid Services (CMS) is now accepting Prescription Drug Data Collection (RxDC) submissions for “reference year” 2023. Data must be submitted through the RxDC Health Insurance Oversight System (HIOS) module. As background, plans and issuers must submit annual spending, premium, and enrollment information based on the “reference year” (i.e., the calendar year immediately preceding the calendar year in which the data submission is due). See our prior update for more background on this reporting requirement. Plans and issuers must submit these reports by June 1 of each year, covering information for the prior calendar year. The first round of reporting (for 2020 and 2021) was due December 27, 2022, and the second round (for 2022) was due June 1, 2023. The next RxDC report (for 2023) is due by Saturday, June 1, 2024. Employers should confirm they are taking steps to comply with this reporting deadline, such as submitting certain plan data on their own through the HIOS portal and providing information to third-party vendors on a timely basis.
Self-Insured Plans Responsible for Reporting
The RxDC reporting requirement applies to both fully insured and self-insured plans, however, fully insured carriers will handle the reporting for their clients. Self-insured plans are responsible for their own reporting and will generally look primarily to their broker for guidance regarding the employer’s compliance and reporting. Self-insured employers will typically use third-party administrators (TPAs), pharmacy benefit managers (PBMs), or other third parties to submit RxDC reports on their behalf. There could be multiple reporting entities involved in compiling and submitting data for an employer self-insured plan, and various vendors are taking different approaches. Some may report aggregated data directly to CMS and others may provide the data to the employer for submission. For example, some vendors will submit all files except the D1 file which includes membership data, employer/employee contributions, and administration and stop-loss costs. If an employer/plan is required to submit any data themselves, they must first set up their organization with a HIOS account. CMS has issued detailed and easy-to-follow instructions which can be found on a CMS RxDC website where FAQs, templates for the data files, and much more information is posted. The CMS help desk is available to assist with the RxDC reporting/submission process (access them by email or telephone at 855-267-1515).
Employer Next Steps
Employers with fully insured medical plans should confirm with their insurance carriers that they will be timely processing the RxDC reporting. Self-insured employers should confirm that their TPA or PBM will be completing an RxDC report on behalf of the plan, and promptly respond to any questionnaires received from the vendors to assist with compiling some of the basic plan information needed in addition to the main content handled by the vendor. Self-insured employers should also be sure to timely submit any plan data themselves as needed through the HIOS portal. Being proactive and communicating with vendor partners to coordinate reporting responsibilities is an essential aspect of this process. A health plan’s submission is considered complete if CMS receives all required files, regardless of who submits them.
Conner Strong & Buckelew is working directly with our health insurance carriers and vendor partners to monitor guidance and confirm approaches to assisting our clients in remaining compliant with these RxDC requirements. As compliance-related questions and issues continue to surface from vendors and employers, we are hopeful that the vendor industry will continue to evolve its processes to provide maximum assistance to the employer community and also that the Departments will continue to provide further guidance, clarifications, and support.
We will provide alerts and updates as new information becomes available. Please contact your Conner Strong & Buckelew account representative toll-free at 1-877-861-3220 with any questions. For a complete list of Legislative Updates issued by Conner Strong & Buckelew, visit our online Resource Center.
