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CAA December 27, 2022 Deadline to Submit RxDC Reporting Information is Fast Approaching

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 prescription drug and health care spending to the Centers for Medicare and Medicaid Services (CMS).

This submission of prescription drug data is called the “RxDC Report.” The deadline to submit this first RxDC Report is December 27, 2022, and covers data for the 2020 and 2021 reference years. For subsequent reference years, the RxDC Report is due by June 1 of the calendar year immediately following such reference year. For example, the deadline for 2022 reference year data will be June 1, 2023.

The RxDC reporting requirement applies to employer-sponsored group health plans, including fully insured, self-funded plans, and non-federal government plans. Employers may use carriers, third-party administrators (TPAs), pharmacy benefit managers (PBMs), or other third parties to submit the RxDC Report on their 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 provide assistance with submitting 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.

Additional Information From CMS

More information, including RxDC reporting instructions, is available on the CMS website. Additionally, CMS will be hosting a live webinar/demo, on Wednesday, December 7, 2022 at 1 pm. EST to train group health plan sponsors and other entities on how to submit the RxDC Report. To register for this webinar, you must first create an account through CMS’s portal REGTAP. Click here to create an account.

If you have questions about this new report, contact your OneDigital consultant. Download the Compliance InfoBrief: Prescription Drug and Health Care Spending Reporting to review the latest regulations on reporting requirements.