March 26, 2024
With the 2023 reference year RxDC reporting deadline approaching soon, plan sponsors should familiarize themselves with recent updates to the RxDC Reporting Instructions.
As a reminder, the Consolidated Appropriations Act, 2021 includes a provision that requires group health plans and health insurance issuers (collectively “plans and issuers”) to report certain specified data related to prescription drug and other health care spending. The first RxDC report (for 2020 and 2021) was due on January 31, 2023, with the report for 2022 following soon thereafter on June 1, 2023. The deadline to submit reporting for calendar year 2023 is June 1, 2024 (and continues each June 1st thereafter).
In anticipation of the June 1, 2024 deadline, the agencies updated the reporting instructions. The most relevant updates are summarized below:
Conclusion In our experience, carriers, TPAs, PBMs and other vendors have varying requirements and expectations of what they need from plan sponsors to successfully complete the reporting, and some may even be delegating some of the reporting responsibility to the plan sponsor. For example, if your insurance company, TPA, or PBM sent you a survey or questionnaire to collect information about plan numbers, premium, or funding types, it is likely that they are reporting the P2 and D1 files on your behalf. Therefore, it is important to respond to any requests for information you may receive and coordinate with your vendors to understand their expectations to ensure all reporting is completed in full on behalf of the plan. If your vendor sent you an email or letter asking you to create a HIOS account or stating that they will not submit P2 and D1 on your behalf, that means you must submit P2 and D1 directly to CMS (or engage a third-party to submit them for you).
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About the Author. This alert was prepared for The Fedeli Group by Barrow Weatherhead Lent LLP, a national law firm with recognized experts on the Affordable Care Act. Contact Stacy Barrow or Nicole Quinn-Gato at sbarrow@marbarlaw.com or nquinngato@marbarlaw.com.
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