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Article last updated: April 27, 2023.
Most of your clients likely have upcoming deadlines under federal prescription drug benefits reporting requirements. Here’s a summary of the requirements, how carriers can help, and the deadlines.
Under Section 204 of the 2021 Consolidated Appropriations Act (CAA), insurance companies and employer-based health plans must submit information regarding prescription drug benefits and health care spending. The information must be submitted to the Centers for Medicare and Medicaid Services (CMS) by June 1st of each year for the prior year’s coverage.
Enforcement of the requirements was relaxed for reports due in 2021 and 2022. The requirements for reports due in 2023 are being enforced. Failure to report can lead to a penalty of $100 per day per affected individual.
A detailed summary on the requirements can be found in this helpful Mercer article (many carrier communications that you and your clients are receiving refer to technical terms such as “P2,” “D2-D8,” etc. This article explains these terms).
Each carrier is taking action to support your employer clients with the federal reporting requirements. In order to do so, they require information from each employer group. The approach being taken by each carrier is similar, but varies in detail, including important deadlines. Here’s a summary:
Aetna
Plan sponsors should fill out this RxDC Plan Sponsor Data Collection form with the required data by April 1, 2023. The required data includes the:
Anthem
Anthem is sending emails to Small Group and Large Group fully insured clients and Anthem Balanced Funding clients, asking them to submit monthly average premium information required for Prescription Drug Data (RxDC) reporting. Anthem clients should complete this form before March 24, 2023.
Blue Shield of California
Blue Shield is providing fully-insured groups and self-funded ASO group plan clients an option for collecting and reporting all the required information on their behalf. Groups electing this option must complete a Blue Shield Intake Form. Blue Shield has provided an Intake Form FAQ.
Blue Shield will submit the data report on behalf of fully-insured and self-funded ASO group plans only if the group provides a complete response to the questions on the intake form by March 31, 2023 by 6:00 pm PST. By completing the form, the employer consents that Blue Shield will submit the data on their behalf to the CMS.
If the employer group does not complete the intake form by March 17, 2023, then the employer group will be responsible for submitting all required data directly to the CMS by June 1, 2023.
More details can be found in emails sent recently by Blue Shield directly to brokers and employer groups.
CaliforniaChoice
The information above from CaliforniaChoice was provided verbally. Until this information is formally posted on the CaliforniaChoice website and especially for employers with Kaiser and Sutter enrollment, who are being advised that no action is required, Claremont strongly recommends that brokers contact the carrier and get formal confirmation as to what reporting assistance the carrier will or will not provide. In all cases, it is strongly recommended that the broker or employer request a receipt that the necessary reporting was indeed filed by the carrier. Keep that receipt in the event of a CMS audit.
Cigna+Oscar
Cigna intends to file on behalf of plan sponsors. No action is required of brokers or employers at this time. Look out for future communications from Cigna and Cigna + Oscar.
Covered California for Small Business
Covered California for Small Business (CCSB) is an administrator of its participating health plans and is not subject to RxDC data collection requirements on behalf of employer groups. CCSB has provided the following information for each of their participating health plans:
More details can be found in this April 11, 2023 CCSB broker email.
Kaiser Permanente
Kaiser Permanente (KP) needs to collect certain data in order to submit all applicable reports and required responses on behalf of employers. Employers with KP coverage in 2022 should complete this form no later than April 3, 2023. The broker can also complete the form on behalf of the employer. Once KP has the necessary data, it will submit all applicable reports and required responses to the CMS by the June 1, 2023 deadline.
Note: Kaiser asks for the data in a different way than other carriers. To help simplify the process, Claremont has created a worksheet (Excel, PDF) with instructions. If the broker or employer can assemble three pieces of data for each month in 2022, they can enter those into the worksheet and it will calculate the answers for Questions 8 and 9 which can then be entered into the Kaiser form.
Sharp Health Plan
Sharp Health Plan will be contacting their employer groups directly to obtain the required information. In addition, they will be sending a broker and employer alert informing all brokers and employers of the RxDC reporting requirement.
UnitedHealthcare
UnitedHealthcare (UHC) will assist clients by submitting all required information to the CMS if the employer completes UHC’s Pharmacy and Benefits and Costs Survey by March 10, 2023.
UHC sent an email communication on February 3, 2023 to all brokers/groups with fully-insured and Level-Funded plans instructing them of the data collection and action required to complete the Survey. Here is a link to the FAQs from UHC. It also links to the survey. Once the survey is complete, UHC will submit the necessary data to the CMS on behalf of the employer prior to the June 1, 2023 deadline.
The carriers are taking action to support your clients with the federal reporting requirements. In order to do so, they require information from each employer group. Look out for emails directly from the carriers, and follow their instructions. If you or your clients have questions, we can help direct you to the right contacts at the carriers.
Questions?
Contact The Answer Team at 800.696.4543 or info@claremontcompanies.com.
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