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” 2023 must be submitted directly to CMS by June 1, 2024, and each June 1st thereafter.
Who this applies to:
- Large employers with fully insured and self-funded health plans
- Small employers with fully insured and level-funded health plans
Go Deeper:
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 2023 reference year (which is data for the 2023 calendar year, regardless of when the plan renews) will be due by June 1, 2024. Helpful information can be found on CMS’s RxDC webpage.
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