April 13, 2023
Under the Consolidated Appropriations Act, 2021 (CAA), health issuers offering group or individual health coverage and self-funded group health plans must submit detailed data on prescription drug pricing and healthcare spending. This data submission
is called the Prescription Drug Data Collection (RxDC) Report.
The first RxDC report was due December 27, 2022 (for reference years 2020 and 2021), with subsequent reporting due annually by June 1. Required entities must submit the report through a web portal managed by the Centers for Medicare & Medicaid Services
(CMS), which will collect the data on behalf of the Departments of Health and Human Services, the Department of Labor, and the Department of the Treasury (the Departments).
The reporting requirements include information intended to identify the significant drivers of increases in prescription drug and healthcare costs, increase understanding of how prescription drug rebates impact premiums and out-of-pocket costs and improve
prescription drug pricing transparency.
The Premera approach
Fully insured, OptiFlex, and Self-funded business
As with the initial reporting, Premera will submit the reference year 2022 report, which is due by June 1, 2023. The report will include plan lists P1-P2, data files D1-D8, and the required narrative response.
Average Monthly Premium Data
The average monthly premium by employer and by member data, previously excluded from the reference year 2020 and 2021 reporting in 2022 due to a safe harbor, will now be required for the June 1, 2023 report. As a courtesy, Premera will collect and report
this data on behalf of our employer groups. If applicable, Premera will also collect and report outside stop loss premium information. Using a survey posted to the employer page of Premera.com, we will be collecting this data from March 29, 2023,
through April 26, 2023, to allow ample time for submissions. This information was communicated to employer groups on March 21, 2023, via the Employer newsletter. A reminder communication will be sent 2 weeks prior to the deadline via e-mail to those
groups who have not yet completed the survey.
Associations
If you are the producer of an association group, please note that Premera is working with the groups TPA’s to collect the needed data from the online survey. Once the data is received, it will be incorporated into the D1 file and submitted on behalf of the groups to CMS by the 6/1 deadline as planned.