The next phase of the Consolidated Appropriations Act is the Prescription Drug Data Collection (RxDC) Reporting provision. The Consolidated Appropriations Act (CAA) requires reports to be submitted beginning December 27, 2022. Health insurers offering group or individual health coverage and self-funded (ASO) group health plans must report annual data on drug utilization and spending trends to the federal government. The reports include spending on prescription drugs and health care services.
Reports will be submitted to the U.S Department of Health and Human Services through its Health Insurance and Oversight (HIOS) system, an application in the Centers for Medicare & Medicaid Services (CMS) Enterprise Portal.
The first reports, due on December 27, 2022, are for calendar years 2020 and 2021.
Anthem did issue a notice to clients earlier this week stating the following:
ASO and Fully Insured Clients
Based on the current reporting instructions, Anthem will submit the aggregated reporting data by market segment on our fully insured and ASO clients’ behalf for the benefits we administer and maintain. This will include submission of the pharmacy data for clients that have integrated pharmacy with IngenioRx through us. If a client has a carve-out vendor for any portion of the required data (e.g., carveout PBM), the client should work with the carveout vendor to ensure submission of that data.
The reports will include client data, but the reporting will not be client specific. The clients included in the reporting will be identified in the required plan reports.
- For self-funded groups, beginning with November 1, 2022, renewals, Anthem will add language to Section B of its ASO Agreement to document that it is undertaking this reporting on the plan sponsor’s behalf.
- For our fully insured policyholders, this notice serves as our agreement to complete this reporting on your behalf for the benefits we administer and maintain.
The notice sent to groups was informational in nature and will require no action by most clients.
If you have any questions, please do not hesitate to contact your Cornerstone Broker Advisor.