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.
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.
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.