eAlert! Federal: Prescription Drug Data Collection Reporting Update

The Consolidated Appropriations Act, 2021 (CAA), Title II, Division BB, included a new annual reporting requirement for group health plans and health insurers to report certain specified data related to prescription drugs and other healthcare spending, known as the prescription drug data collection (RxDC). The 2023 reference year (calendar year) RxDC data report is due by June 3, 2024. Typically, carriers, third-party administrators, or pharmacy benefit managers submit the data on behalf of a plan sponsor and therefore may request additional information from employers to complete the process.

The Centers for Medicare and Medicaid Services (CMS) published the 2023 reference year instructions. The key updates include:

1. Exclusion of certain products: Clarification that medical devices, nutritional supplements, and over-the-counter drugs are to be excluded from the prescription drug lists (sections D3, D4, D5, D7, and D8) unless the product’s National Drug Code (NDC) is listed on the CMS Drug and Therapeutic Class Crosswalk.
2. Simplification of premium calculation: The method for calculating the average monthly premium has been simplified. Instead of calculating this on a per-member basis, the total annual premium is now divided by 12.
3. Modification of premium equivalents calculation: The calculation for premium equivalents has been simplified by removing the requirement to report on a cash basis and using paid claims rather than incurred claims.
4. Updates to benefit carve-out field: Instructions for filling out the benefit carve-out field in section P2 have been updated.
5. Clarification on reporting prior year and restated rebates: Additional details have been provided on how to report information in the prior year columns in section D5 and the restated rebate columns in sections D6, D7, and D8.
6. Guidance on retained rebates reporting: New instructions have been provided for reporting entities on how to report information on retained rebates when exact amounts are unknown.
7. Submission of large data files: Instructions on how to submit data when plan list or data files exceed the maximum allowable size limit in the Health Insurance Oversight System (HIOS) have been included.
8. Enforcement of aggregation restriction: The enforcement of the aggregation restriction has been announced, which pertains to how data are aggregated for reporting purposes.
9. Addition of enrollment column to D6: A new column to collect enrollment data has been added to section D6.

Read more on the CMS Prescription Drug Data Collection (RxDC) web page, and see the GHP: Prescription Drug Data Collection and Reporting page.