RxDC Reporting: What Employers Need to Do Now
February 13, 2023
While the deadline for the 2020 and 2021 Prescription Drug Data Collection (RxDC) reporting may have just passed, employers should be aware of another impending deadline – this one imposed by many carriers and TPAs – as it relates to the upcoming 2022 RxDC reporting. Paying attention to this now may save employers a lot of work later this spring.
Carriers and TPAs took care of the majority, if not all, of the filing requirements for the initial reporting for calendar years 2020 and 2021. They were able to do this because the government issued relief stating information on premiums paid by employers and premiums paid by members was not required for those years. However, no such relief has been issued for the 2022 reporting.
Since carriers and TPAs generally will not have information on how much an employer collected from members (including employee contributions, COBRA premium payments, etc.), some have announced they will not file that information on behalf of employers, leaving employers to file those data elements on their own.
Other carriers and TPAs may agree to file on behalf of employers, but only if they receive the needed information from an employer by a certain date—some as early as March 1—otherwise those employers will also be responsible for filing those data elements on their own.
Immediate Steps for Employers
Employers should confirm with their medical carrier and/or TPA whether or not they will submit file D1: Premium and Life Years (D1) on their behalf. This is the file that contains the employer and member premium information.
We anticipate that most fully insured carriers – and some self-funded carriers and TPAs – will submit file D1 on behalf of employers, as long as they receive the required information from the employer by their deadline. Many carriers and TPAs have already begun reaching out to employers to collect this data, and they are imposing hard and fast deadlines for responses. If employers do not submit information by the vendor’s deadline, the employer will likely be responsible for filing those data elements on their own.
Employers responsible for submitting their own D1 file will need to create an account on the Health Insurance Oversight System (HIOS) through the CMS website, as data is submitted through the RxDC HIOS Module. This can take up to 2 weeks to process, so we recommend starting the process early if you know you will be responsible for submitting data. To create a HIOS account, visit the CMS.gov Enterprise Portal and click the blue “New User Registration” button.
How and When to File RxDC Data
The deadline to file RxDC reporting for 2022 is June 1, 2023. CMS has indicated they expect to start accepting 2022 submissions sometime in April and that updated instructions will be released prior to that. No changes to the templates are anticipated, and no substantive changes are expected relative to the instructions. Employers responsible for filing their own D1 file will also need to include file P2: Group Health Plan List (P2) as it acts as a “cover page” for the submission.
Once the instructions and templates are released for the 2022 filing, Hylant will support our clients by providing a video that will explain how to complete and submit files P2 and D1.
The CMS RxDC website includes multiple resources including reporting instructions, HIOS manuals and the RxDC templates. We expect the updated materials for the 2022 filing will also be housed on this website once they are released.
The above information does not constitute advice. Always contact your employee benefits broker or trusted adviser for insurance-related questions.
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