Prescription Drug Reporting
The No Surprises Act, which is a part of the Consolidated Appropriations Act, require group health plans share information about their prescription drug and healthcare spending to the Department of Labor (DOL), Health and Human Services (HHS), and the Treasury.
These rules apply to group health plans and health insurance companies in both individual and group markets. The required sharing of information is done through a “prescription drug data collection” or “RxDC report.” The first RxDC report was due by December 27, 2022. The most recent RxDC report was due by June 1, 2023. Did your company remember to comply?
Reporting on Pharmacy Benefits & Drug Costs
According to interim rules, employers have the option to use insurance companies, third-party administrators (TPAs), pharmacy benefit managers (PBMs), or other third parties to submit the RxDC reports on their behalf. Employers can submit these reports themselves, however it is more common for their carriers to submit these reports for them. Employers will want to work with their provider or broker to understands who is taking on this responsibility. The data collected will be used to identify major drivers of prescription drugs, health care spending, understand how drug rebates impact premiums and out-of-pocket costs, and promote transparency in prescription drug pricing. The information that is being reported on:
Information on the plan or coverage, such as the beginning and end dates of the plan year, the number of participants, beneficiaries or enrollees (as applicable), and each state in which the plan or coverage is offered.
The 50 brand prescription drugs most frequently dispensed by pharmacies for claims paid by the plan and the total number of paid claims for each drug.
The 50 most costly prescription drugs with respect to the plan by total annual spending and the annual amount spent by the plan for each drug.
The 50 prescription drugs with the greatest increase in plan expenditures over the prior plan year and, for each drug, the change in amounts expended by the plan in each plan year.
Total spending on health care services by the group health plan, broken down by the type of costs; the average monthly premium paid by employers (as applicable) and by enrollees; and any impact on premiums by rebates, fees and any other remuneration paid by drug manufacturers to the plan.
Any reduction in premiums and out-of-pocket costs associated with rebates, fees or other remuneration.
According to the Departments, this data will help them identify major drivers of prescription drug and health care spending, understand how drug rebates impact premiums and out-of-pocket costs, and promote transparency in prescription drug pricing.
Does the reporting requirements apply to all plans?
Who is responsible for self-funded plans?
Compliance can be very challenging for employer groups of all sizes. If you are would like to work with a broker that specializes in compliance please reach out today.