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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.

CA Bereavement Leave as of January 2023

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Starting Jan 1, 2023, employers with five or more employees must abide by new bereavement leave provisions. This is due to an amendment that was made to California Family Rights Act (CFRA) on September 29, 2022. This modification included the implementation of Assembly Bill No. 1949 (AB-1949). Under this bill, eligible employees may take up to five days of bereavement leave as a result of the death of a family member.

 

Overview

The following information outlines the implications of a bereavement leave:

  • A leave must be completed within three months of the dated death
  • Leave may be unpaid however, employees are entitled to use other leave balances, such as available sick leave
  • Days taken for leave are not required to be taken consecutively
  • The leave must be taken in accordance with any current leave policy, with the assurance that the employee is granted no less than five days of bereavement leave.
  • An employee must provide documentation of the death of a family member within 30 days of the first leave if requested by an employer.
  • A covered employer is required to maintain confidentiality regarding the employee’s request and documentation for bereavement leave.

 

This Bereavement Leave Update 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.

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