Second Rx Report Due June 1, 2023

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Health plan and health insurance issues must submit their second prescription drug data report by June 1, 2023, as part of the annual reporting requirements. Employers and insurance carriers will generally submit these reports on an annual basis no later than June 1st of each year, reporting information for the prior calendar year.

 

RxDc Compliance Guide

To comply with the RxDC reporting requirements, employers should consider doing the following:

  • Contact issuers, such as TPAs o PBMs, to ask if they will submit the report for your health plan
  • Ensure your third-party RxDC submission agreement is updated
  • Monitor the third party’s adherence to the RxDC reporting requirement for self-funded health plans.
  • Provide any information that is requested by the third party submitting the RxDC report for your health plan as soon as possible.

 

Third Party Issuers

Health plans can use third-party issuers, such as TPA and PBM, to submit an RxDc report on their behalf. Health plans may submit RxDC reports on their own, but the occurrence is uncommon. The following information outlines procedures and rules that should be considered when using an issuer:

  • A formal agreement between the plan and the third party must be constructed to address this reporting obligation.
  • The issuer, not the plan, is in violation of the reporting requirements if it fails to submit the RxDC report when required to do so.

 

General Deadlines

The initial RxDC report was due December 27, 2022, with a grace period through January 31, 2023. The first report should contain prescription drug data from 2020 and 2021. The second RxDC report should contain prescription drug data from 2022 and meet the June 1, 2023 deadline.

 

Resources

CMS.gov provides the following resources:

  • On Nov. 23, 2021, the Departments published an interim final ruleregarding the requirement to report pharmacy and drug costs.
  • Transparency in coverage FAQswere released on Aug. 20, 2021.
  • An FAQabout the submission grace period and reporting flexibilities for 2020 and 2021 data was released on Dec. 23, 2022.
  • More information, including RxDC reporting instructions, is available through the HHS’ RxDC website.
  • Prescription Drug Data Collection (RxDC) Reporting Instructions: https://regtap.cms.gov/reg_librarye.php?i=3860

 

For more information on this topic, please contact MNJ Insurance Solutions.

This Rx reporting summary is provided for informational purposes only and should not be construed as legal or a recommendation of any kind. While we have attempted to provide current, accurate, and clearly expressed information, this information is provided “as is,” and MNJ Insurance Solutions makes no representations or warranties regarding its accuracy and completeness.

COVID-19 National and Public Health Emergencies Will Terminate May 11, 2023

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While California’s COVID-19 state of emergency ended on February 28, 2023, the national COVID-19 Public Health Emergency is still active and will terminate on May 11, 2023. Consumers impacted by the COVID-19 Public Health Emergency may qualify for Special Enrollment using the “Public Health Emergency” Qualifying Life Event to enroll and make changes to their coverage.

The Department of Labor’s Employee Benefits Security Administration (EBSA) is committed to working with employers and other plan sponsors to ensure a smooth transition as the federal government unwinds some of the policies that have been in place during the COVID-19 public health emergency and National Emergency. To partner with you through this process, the Departments of Labor, Health and Human Services, and the Treasury issued guidance today in an effort to ensure that workers and their families are aware of any changes that may be coming their way:

 

As a reminder, states that administer Medicaid, such as Medi-Cal in California, were prohibited from terminating a beneficiary’s enrollment during the national COVID Public Health Emergency unless they moved out of state, became deceased, or the beneficiary requested a voluntary termination of eligibility. Beginning as of April 1, 2023, the Department of Health Care Services will begin to “unwind” this policy and resume its annual eligibility review process for members enrolled in Medi-Cal, which could possible result in a beneficiary being determined no longer eligible for Medi-Cal.  This would allow eligible individuals to enroll in a qualified health plan and possibly gain eligibility for advanced premium tax credits with a July 1, 2023 effective date.  The other option for members who lose eligibility with Medi-Cal is they could enroll in their employer group plan (if they meet the employer’s eligibility requirements), as this is a qualifying life event.  Please reference Covered California’s Public Health Emergency & Medi-Cal to Marketplace Automatic Enrollment Program Toolkit for additional program information and support materials.

 

If you have any questions or would like more information, please reach out to MNJ Insurance Solutions.

 

This summary is provided for informational purposes only and should not be construed as legal or a recommendation of any kind. While we have attempted to provide current, accurate, and clearly expressed information, this information is provided “as is,” and MNJ Insurance Solutions makes no representations or warranties regarding its accuracy and completeness.