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RxDC Reporting Deadlines

Mar 19, 2024, 5 Minute Read

Article last updated: March 19, 2024.

Most of your clients likely have upcoming deadlines under the federal prescription drug benefits reporting (RxDC) requirements. Here’s a summary of the requirements, how carriers are helping, and the deadlines.

General Information

Under Section 204 of the 2021 Consolidated Appropriations Act (CAA), insurance companies and employer-based health plans must submit information regarding prescription drug benefits and health care spending. The information must be submitted to the Centers for Medicare and Medicaid Services (CMS) by June 1st of each year for the prior year’s coverage.

According to the CMS, the information that is required to be submitted by insurance companies and employers are:

• Spending on prescription drugs and health care services.
• Prescription drugs that account for most spending.
• Drugs that are prescribed most frequently.
• Prescription drug rebates from drug manufacturers.
• Premiums and cost-sharing that patients pay.

CMS Resources

• CMS Prescription Drug Collection Reporting Page
• CMS Prescription Drug Collection RxDC Reporting Instructions
• CMS Prescription Drug Data Collection FAQs
• CMS Help Desk – CMS FEPS@cms.hhs.gov
• CMS Enterprise Portal

Blue Shield

Blue Shield will collect D1 Premium information from groups between February 5, 2024 and April 19, 2024. Blue Shield will also submit D2 for all groups and D3-D8 for groups with prescription drug benefits under a Blue Shield health benefit plan, and P2 accordingly. If a group does not have prescription drug benefits with Blue Shield, they should coordinate submission of D3-D8 with their pharmacy/prescription drug benefits carrier, and P2 accordingly.

Key Details

• Covered CA Small Business groups, whether active or inactive with Blue Shield, are required to fill out this intake form, using the group ID and following web key: #24yr23.
• All other groups (Off-Exchange/non-Covered California plans) are required to follow the process below:
  • Active groups have two options:
    1. Complete this form using web key #24yr23.
    2. Complete the intake form available on Employer Connection upon logging in.
  • Inactive groups (terminated on or before December 31, 2023) are required to fill out this intake form, using the group ID and following web key: #24yr23.
• The deadline to provide information is Friday, April 19, 2024 at 6:00 PM (PST).
• Blue Shield is not accepting paper, PDF, or fax submissions. If you, or the group, previously provided a response through either of these methods, please resubmit this information through the process outlined above.

Other Details:

• For group plan sponsors whose benefit structures include multiple groups (subgroups), the intake form must be completed for the group, not the subgroup, under the main ID.
• Only one individual (broker, group administrator, or delegate) may submit responses for a single group ID.
• A single broker or delegate may, however, submit a response for multiple groups.

Information Requested

• Basic group information such as group name and group ID.
• Healthcare premium percentage paid by the employer for Small Business Groups and Large Groups that have prescription drug benefits with Blue Sheild or,
• Total healthcare premium paid by employer and employee, for Large Groups that have pharmacy/prescription drug benefits with another carrier besides Blue Shield.
• Total Premium Equivalent Amount (for self-funded ASO only, when applicable) – Total cost of providing and maintaining coverage, including claims costs, administrative costs, self-funded ASO and other TPA fees, and stop-loss premiums.
• Blue Shield 2024 RxDC D1 Intake Form FAQs
• Blue Shield 2024 RxDC Responsibility Matrix
• Blue Shield Employer Connection
• Blue Shield 2024 RxDC Reporting Intake Form – Terminated Groups

UnitedHealthcare

Due to technical issues on their end and updated guidance from CMS about the 2024 submission, below are revised dates:

• The opening of the Request for Information (RFI) tool is Wednesday, February 14, 2024.
• The deadline for employers/brokers to complete submissions (or to contact UHC to request data) is Wednesday, April 10, 2024.

UnitedHealthcare will complete the CAA Prescription Drug (RxDC) reporting for its fully insured and self-funded/level funded groups, including those with OptumRx as the integrated PBM. However, groups with these will need to complete the Request for Information (RFI) tool for RxDC reporting between February 1, 2024, and March 31, 2024. The March 31, 2024, deadline is firm.

To support its customers with this important filing, UnitedHealthcare will be submitting the P2 (Group Health Plan), D1 (Premium and Life Years) and D2 (Spending by Category) files for all employers who had active coverage during the reference year (2023). However, completion of the submission requires gathering some information not currently maintained in their system.

UnitedHealthcare will also submit the D3-D8 data files for customers with OptumRx as an integrated PBM. UnitedHealthcare has access to all data required to complete the submission of the D3-D8 data files. Customers who use any other PBM, including OptumRx Direct, must work with that PBM to submit the D3-D8 files.

Resources

• 2024 UnitedHealthcare Approach to CAA Prescription Drug Data Collection RxDC Reporting Website
• UnitedHealthcare RxDC Reporting FAQs

Kaiser Permanente

Kaiser Permanente is required to submit information on prescription drugs and healthcare spending to CMS. On February 1, 2024 Kaiser Permanente began to send out a survey form from Kaiser-Permanente-RxDC@kp.org to all contract signers to request this information. The form must be completed by March 15, 2024.

Information Requested

• Average monthly premium that is paid by employee/member.
• Average monthly premium that is paid by the employer/group.
• Employer/group Form 5500 Plan Number (if applicable).

Kaiser Permanente plans to submit all applicable reports and required responses for all employer groups to CMS by the June 1, 2024 deadline.

Sutter Health Plus

Employer groups must submit information to Sutter Health Plus regarding the average monthly premiums paid on behalf of enrollees and the amount paid by enrollees each year.

For calendar year 2023 reporting, employers or brokers are to submit the required information through the online Premium Reporting Form.

Submissions are due no later than March 1, 2024.

Cigna + Oscar

Cigna is reporting on behalf of Cigna + Oscar groups, so no action is required by employer groups or brokers.

Covered California for Small Business

Covered California for Small Business (CCSB) serves as an administrator of their participating Health Plan Issuers and is not an insurance company nor an employer-based health plan. Therefore, CCSB is not subject to RxDC data collection requirements on behalf of their employer groups. Claremont recommends that the employer follow the reporting guidelines for the enrolled carrier(s).

• Blue Shield of California 800.559.5905
  Blue Shield of California issued a Broker Alert detailing instructions for the submission of group data via an intake form. The deadline for the submission of this form is Friday, April 5, 2024 at 6:00 PM PST.
• Kaiser Permanente 800.464.4000
  Kaiser Permanente is compiling and submitting the required data on behalf of their employer groups.
• Sharp Health Plan 800.359.2002
  Sharp Health Plan will be contacting their employer groups directly to obtain the required information. In addition, they will be sending a broker and employer alert informing all brokers and CCSB employers of the RxDC reporting requirement.

CCSB Resources – CCSB’s Small Business Service Center is available to help with questions at 855.777.6782.

CaliforniaChoice

CaliforniaChoice serves as an administrator of their participating Health Plan Issuers and is not an insurance company nor an employer-based health plan. Therefore, CaliforniaChoice is not subject to RxDC data collection requirements on behalf of their employer groups. Claremont recommends that the employer follow the reporting guidelines for the enrolled carrier(s).

• Anthem – Anthem will file on behalf of their fully insured and ASO clients for the benefits they administer and maintain. This includes ASO groups who opt-in to the D1 reporting. In order to submit all required information and ensure reporting accuracy, Anthem will request some information from clients via email that will link to an online form.
• Cigna + Oscar – Cigna is reporting on behalf of groups. No action required by employer or broker.
• HealthNet – HealthNet is reporting on behalf of groups. No action required by employer or broker.
• Kaiser – see above.
• Sharp Health Plan – no details released yet.
• Sutter Health Plus – see above.
• UnitedHealthcare – see above.
• Western Health –  the carrier will reach out to the employer group for any additional.

Summary

The carriers are taking action to support your clients with the federal reporting requirements. In order to do so, they require information from each employer group. Look out for emails directly from the carriers, and follow their instructions. If you or your clients have questions, we can help direct you to the right contacts at the carriers.

Contact us today for assistance.

Questions?
Contact The Answer Team at 800.696.4543 or info@claremontcompanies.com.

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