To comply with the Consolidated Appropriations Act of 2021 (CAA), insurance carriers for fully insured plans and Third Party Administrators (TPAs) for self-funded health plans (except HRAs), must submit e-identified prescription drug data collections (RxDC), to the federal government, by mandated deadlines. The government’s ultimate goal is to identify prescription drug trends in a comprehensive annual report without specifically naming plans, plan sponsors or members. This Compliance Alert focuses on fully insured plan sponsors’ attention to carriers’ time-sensitive data requests.
Good Faith RxDC Reporting Standard Expired
Because regulatory agencies allowed “good faith” submissions of RxDC reports for 2021 and 2021 by January 31, 2023, most carriers filed them with few concerns for precise details. However, for 2022, carriers must currently collect and submit accurate and specific group health plan information to submit by June 1, 2023.
Do not Ignore Requests From Your Insurance Carrier
Most carriers are submitting prescription drug data on behalf of clients who sponsor fully insured plans. Because deadlines cannot be ignored, essential plan data must be collected by carriers promptly. Therefore, carriers are emailing time-sensitive surveys to plan sponsors to gather specific information. Employers with fully insured group health plans must take prompt action to answer their carrier’s data requests.
What Type of Information May be Requested from Carriers?
Each carrier is requesting a slightly different menu of data. In general, the following is being requested:
- Group Name and Number
- Average monthly premiums paid by members and the employer for 2022
- Form 5500 Plan Number, when applicable
What happens if employers don’t answer carriers promptly?
If carriers don’t receive requested plan data on time, plan sponsors will be responsible for submitting their own RxDC reports by registering with the Centers for Medicare and Medicaid Services (CMS) Health Insurance Oversight System (HIOS), gathering and uploading the appropriate prescription drug data while following required instructions. This may be quite a burdensome process for employers.
We strongly recommend that plan sponsors respond promptly to RxDC data requests from insurance carriers. For example, Blue Cross Blue Shield of Michigan (BCBSM) must have survey responses by April 14, 2023 to submit prescription drug data for customers by June 1, 2023. If you have not yet received a request for RxDC data, notify your carrier. If you have questions regarding your time sensitive RxDC reporting, contact your carrier or Valerie Bruce Hovland, Salus Group’s Compliance Manager at [email protected].