Q: Prescription Drug Reporting, required as part of the Consolidated Appropriations Act, for calendar year 2023 is due June 1, 2024. Are the reporting requirements different from what was reported for 2022? Who is responsible for providing the information?

A: The Prescription Drug Reporting requires group health plans to report information on prescription drugs as well as certain elements of health care spending. The requirements on what to report have not changed. Employers who had an Individual Coverage Health Reimbursement Account (ICHRA) in 2023 will not need to report any information for the period in which they had an ICHRA. If the employer had a traditional group health plan prior to the ICHRA at any time in 2023, you will need to be sure to complete the information with your prior insurance carrier or TPA.

The insurance carriers and TPA’s will provide and in some instances have already  provided Employers with a request for the employer information they need to complete the filing Employer groups will need to provide the insurer and Third-Party Administrators (TPA), who are doing the filing for employer sponsored plans, with employer data fields by the required deadline. The claims cost for prescription drugs and health care spending will be provided by the insurance company or third-party administrators. 

Employers need to be sure to meet the deadline provided by their carrier or TPA so they can include your group in their filing with CMS.  If you miss the deadline you will be required to file all or certain required files directly on the Centers for Medicare and Medicaid Services (CMS) website. Liberty Insurance Agency Benefit clients can reach out to their account service manager to ensure that they do not miss this deadline.

If a group misses the deadline provided by their insurance carrier or TPA , the following steps will need to be taken:

• Set up an account with CMS at https://portal.cms.gov/portal/
• Complete the required spreadsheets found at https://www.cms.gov/marketplace/about/oversight/other-insurance-protections/prescription-drug-data-collection-rxdc. Groups will want to reach out to their provider/TPA to see what files they will be required to file.

Fully-insured plans will most likely need to complete the files entitled D1-Premium-and-Life-Years-06-28-20222 and P2-Group-Health-Plan-List-01-31-20242 found under Primary Resources at the CMS Page Prescription Drug Data Collection (RXCD). Groups who must file on the website will want to review the Prescription Drug Data Collection (RxDC) Reporting Instructions and download the RxDC Templates and Data Dictionary (ZIP). Self-insured plans will need to reach out to their TPA to determine which files they will be required to complete to meet the June 1st filing deadline.