Section 204 of the Consolidated Appropriations Act (CAA) requires group health plans and issuers to report detailed prescription drug data, but also requires information related to healthcare spending. The next round of reports for data during the “reference year” 2022 must be submitted directly to CMS by June 1, 2023, and each June 1st thereafter.
Recent FAQs confirmed that the Departments will provide a submission grace period through January 31, 2023, and will not consider a health plan or issuer to be out of compliance as long as a good faith submission of the 2020 and 2021 data is made on or before Tuesday, January 31, 2023. The flexibility only applied to 2020 and 2021 submissions. No such relief has yet been issued for 2022 data submissions due by June 1, 2023.
In order to comply with this requirement, employers must rely heavily on vendors, TPAs, and PBMs because these service providers possess the required data. Any gaps in submissions should be addressed by either the employer submitting themselves in HIOS or engaging with a third-party vendor to assist with coordinating submissions. Employer plan sponsors, especially self-funded health plan sponsors, should continue to take necessary steps in order to prepare for the June 1st deadline.
Again, RxDC submissions for the 2022 reference year (which is data for the 2022 calendar year, regardless of when the plan renews) will be due by June 1, 2023. Helpful information can be found on CMS’s RxDC webpage.