Hi Friends, in the hustle and bustle of back to school, we wanted to use this month to bring you a public service announcement. Among the CAA’s many new compliance requirements for health plans is a significant reporting obligation that is “sneaking up” on the industry. The reports, called the RxDC (Prescription Drug Data Collection) reports, need to be filed by all group health plans, including governmental plans and church plans. Two reports are due on December 27, 2022, the reports on the 2020 and 2021 calendar years. After that, reports are due by June 1 annually. TPAs and PBMs will be primarily responsible for producing the data needed for these reports. Still, plan sponsors are responsible for ensuring that the appropriate data is reported to CMS. And, in our professional assessment—it doesn’t seem like many folks are ready for this. In our not so professional assessment—we are honestly a little freaked out. This is a big deal… why are so few people talking about it? Are we imagining this whole thing?!!
We are pretty sure we aren’t imagining things. This was confirmed when CMS issued an updated user manual for the reporting portal just this month. So, this month, in lieu of our traditional missive—we wanted to share first with you, our friends, this white paper explaining the RxDC reporting requirements in detail. We do recommend sitting down for this. We’ll be here for you friends if you need to talk after.
