March 16, 2023
Under the Consolidated Appropriations Act, 2021 (CAA), health issuers offering group or individual health coverage and self-funded group health plans must submit detailed data on prescription drug pricing and healthcare spending. This data submission is called the Prescription Drug Data Collection (RxDC) Report.
The first RxDC report was due December 27, 2022 (for reference years 2020 and 2021), with subsequent reporting due annually by June 1. Required entities must submit the report through a web portal managed by the Centers for Medicare & Medicaid Services (CMS), which will collect the data on behalf of the Departments of Health and Human Services, the Department of Labor, and the Department of the Treasury (the Departments).
The reporting requirements include information intended to identify the significant drivers of increases in prescription drug and healthcare costs; increase understanding of how prescription drug rebates impact premiums and out-of-pocket costs; and improve prescription drug pricing transparency.
The Premera approach
As with the initial reporting, Premera will submit the reference year 2022 report, which is due by June 1, 2023. The report will include plan lists P1-P2, data files D1-D8 and the required narrative response.
Average monthly premium data
The average monthly premium by employer and by member data, which excluded the reference years 2020 and 2021 for the reporting in 2022 due to a safe harbor, will now be required for the June 1, 2023 report.
To gather additional data needed for reporting this year, Premera will be implementing a survey for groups to fill out. The survey link will be located on the employer page of the Premera website. The survey will be available beginning March 29, 2023, for a total duration of 4 weeks to allow ample time for submissions.All responses are due by April 26, 2023.
Groups with pharmacy carved out
Employer groups that have pharmacy benefits carved out – when pharmacy benefits are separated from medical benefits and managed outside of their organization's primary medical health plan – should coordinate with other carriers to ensure they report all required information.
As with last year’s reporting, Premera will continue to report the below reporting on groups behalf for reference year 2022 by the 6/1/23 deadline.
- P2-Group Health Plan List
- D1-Premium and Life Years
- D2-Spending by Category
- Narrative response
Please contact your Premera representative or producer if you have questions about this requirement.