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2022 RxDC Reporting Due June 1, 2023

Is your organization prepared for RxDC reporting this year?

The Consolidated Appropriations Act, 2021 (CAA-21) requires group health plans and health insurers offering group or individual health insurance coverage to annually submit information about their plan’s prescription drug and healthcare spending to the Centers for Medicare and Medicaid Services (CMS).

The RxDC reporting requirement applies to all employer-sponsored group health plans, including fully insured, self-funded plans, and non-federal government plans.

Employers may contract with carriers, third-party administrators (TPAs), pharmacy benefit managers (PBMs), or other third parties to submit the RxDC Report on the employer’s behalf.

Employers with fully insured plans should confirm that their medical plan carrier will complete the reporting on the plan’s behalf. Employers with self-insured plans should reach out to their TPAs and/or PBMs to determine if these vendors will help submit the RxDC Report.

The RxDC Report will be submitted through the prescription data collection module on the Health Insurance Oversight System (HIOS) located on the CMS Enterprise Portal. Employers do not need to create a HIOS account if a third party is reporting on their behalf. However, if any portion of the report is not being submitted by the TPA or other service provider, the employer will have to submit the data through HIOS.

The most recent instructions state that submissions can only be made through the HIOS system. Email submissions are no longer accepted. Employers that have yet to establish a HIOS account are encouraged to create one as soon as possible.

As covered in our blog post “Departments Announce Grace Period and Clarifications for RxDC Reporting,” the DOL, HHS, and IRS (the Departments) recently gave much-needed clarification and flexibility to certain aspects of RxDC reporting, including:

Allowing Multiple Submissions by the Same Reporting Entity.

The interim final rules stated that reporting entities should only create one submission in HIOS. The Departments have clarified that if a reporting entity submits on behalf of multiple plans or issuers in a reference year, the entity may create more than one HIOS submission for that reference year. Reporting entities do not need to include all data from all clients in a single submission.

Allowing Submissions by Multiple Reporting Entities.

Some employers have contracted with more than one reporting entity to submit RxDC reports. The RxDC instructions previously stated that only one data file should be submitted amongst all parties working on behalf of a plan. However, the FAQs clarify that more than one reporting entity can submit the same data file type for the same plan or issuer. For example, two reporting entities can now submit a D1 file where previously only one D1 file was allowed to be submitted. Employers do not need to ensure that multiple reporting entities are working together to consolidate all data into a single file.

As of this writing, CMS has not provided general or specific good faith relief for 2022 reporting.

Plan sponsors are encouraged to continue to work with their vendors between now and June 1, 2023, to ensure compliance with RxDC reporting requirements.

To review the latest regulations on reporting requirements, download the Compliance InfoBrief: Prescription Drug and Health Care Spending Reporting.