NEWSROOM

The Consolidated Appropriations Act (CAA) of 2021 created a myriad of new compliance requirements for health plans and insurance issuers, aiming to increase “transparency” in health care. One key requirement is the Rx Data Collection (RxDC), which requires plans and issuers to report on prescription drug and health care spending for the 2023 calendar year by June 1, 2024. This applies annually, with future deadlines falling on June 1st of each year.

Group plans and issuers must report:

• P2 – Plan information: Name, sponsors, and EINs, market segment, state, plan year, number of participants
• D1 – Gross premiums and employer/employee contributions
• D2 – Total health care spending
• D3 – Top 50 most-frequently dispensed brand-name drugs
• D4 – Top 50 most costly drugs
• D5 – Top 50 drugs by spending increase
• D6 – Prescription spending and utilization – by the plan and participants
• D7 – Prescription drug rebates, fees, etc.
• D8 – Prescription rebates for the top 25 drugs with the highest amount of rebates

Insurance carriers in the fully insured group market handle most, if not all, RxDC reporting items for their employer clients. However, their methods and approaches vary. Most carriers, needing to report employer/employee contributions, are requesting employers to complete a survey to verify data accuracy prior to reporting.

Employers that do not respond to carriers’ requests for information may have to file the complex P2 and D1 reports themselves, possibly requiring legal counsel and intel from the carrier. Employers with self-funded plans typically need to create these reports themselves, usually in consultation with their Administrative Services Only (ASO) provider, their Pharmacy Benefit Manager (PBM), and legal counsel.
 
The Centers for Medicare & Medicaid Services (CMS) has updated its RxDC Reporting Instructions Guide to aid plans and issuers in the reporting process, and has other general information on its CAA RxDC website.
 
Word & Brown has gathered fully insured carrier updates on Rx Data Collection practices, including deadlines and important details as applicable. We anticipate further developments and will keep this information updated throughout the reporting season.

Aetna

1. Will you be filing the D2 file for your fully insured clients?
   • Yes 
2. Will you survey your group clients to verify employer contributions for the D1 filing?
   • Survey: Yes
     • Plan sponsor communication will go out starting on 3/15/24. Each plan sponsor will receive an email with a link to provide the required information. The plan sponsor will need to complete the information.
   • Deadline
     • April 12, 2024.
   • What happens if an employer misses the deadline?
     • We will file on their behalf with the information we have, it is their responsibility to file the additional details with CMS directly.
3. How can employers confirm their CAA RxDC files have been filed?
   • We will file by the required deadline of 6/1/24, however we will not provide confirmation.
4. Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
   • Brokers will not be cc’d on the emails to request information from their employer groups. The email includes a link to fill out the information that is specific to the plan sponsor.

Anthem Blue Cross (CA)

1. Will you be filing the D2 file for your fully insured clients?
   • Yes 
2. Will you survey your group clients to verify employer contributions for the D1 filing?
   • Survey: Yes
     • Please fill out our data submission form to make sure we have the needed information.
   • Deadline
     • March 15, 2024.
3. How can employers confirm their CAA RxDC files have been filed?
   • The week of June 3, 2024 – Confirmation of RxDC filing: We will email all Fully Insured and ASO commercial groups, including National Accounts, Large Group, and Small Group clients, to notify them that we have completed the required 2023 filing of prescription drug data on their behalf in compliance with the federal regulations. This information will also be published to Employer Access Latest News (employer login required).
4. Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
   • Anthem Blue Cross – Broker Alert 2-7-24
   • Anthem Blue Cross – CAA/Transparency Resource Center (must select correct state to access resource)
5. For CalChoice employers: Will you request information to facilitate 2023 CAA Rx DC reporting? If so, please specify the information and deadlines.
   • CHOICE provided Anthem with the requested data report. No additional action is needed by CHOICE groups.

Blue Shield of California

1. Will you be filing the D2 file for your fully insured clients?
   • Yes: Blue Shield will submit D2 for all groups and D3-D8 for groups with prescription drug benefits under a Blue Shield health benefit plan. If a group does not have prescription drug benefits with Blue Shield, it should coordinate submission of D3-D8 with the pharmacy/prescription drug benefits carrier.
2. Will you survey your group clients to verify employer contributions for the D1 filing?
   • Survey: Yes
     • Active groups will need to fill out the intake form available on Employer Connection upon logging in. Terminated groups will need to fill out the intake form, using this link, also sent to them via email. This can also be found by visiting Employer Connection and clicking the "go" button. Termed groups will need to follow this process as opposed to logging in via their Employer Connection account, as termed groups may no longer have access to an Employer Connection account to complete the intake. Termed groups will need to use a Blue Shield group ID and the web key provided via email.
   • Deadline
     • Friday, April 5, 2024, at 6:00PM (PST)
   • What happens if an employer misses the deadline?
     • Groups that miss this deadline will not be included in Blue Shield’s filing and may be subject to non-compliance if not reporting the required data directly to CMS. The group will be responsible for submitting D1 data directly to CMS by the June 1, 2024, deadline.
   • Will you communicate with employers who miss the deadline? If so, how, and when?
     • We will send out reminders to those that have not responded on 3/7 and 3/28; after that, no additional reminders are scheduled at this time.
   • What type of communication will you send to employers about this?
     • We plan to send the information via an employer alert.
3. How can employers confirm their CAA RxDC files have been filed?
   • A confirmation email will be sent to the submitter and will include a snapshot of their responses along with a link to edit the survey until April 5, 2024. This confirmation can be sent by the submitter to the group as confirmation emails will only be sent to the individual submitting responses.
   • Blue Shield of California has successfully submitted data reports to the CMS. Blue Shield has reached out to groups informing them of the data submission for their records and brokers through their Broker Alert.
4. Can employers access copies of their P2 and D1-D8 files once they have been filed?
   • The information submitted is aggregate information, so it will not be available.
5. Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
   • Blue Shield of California – Prescription Drug Costs Reporting FAQ.
   • Blue Shield of California - Broker Alert 2-5-24
   • Blue Shield of California - RxDC Responsibilities Matrix
6. How can employers and brokers with questions about your processes contact you for more information and support?
   • They can contact producer service (800-559-5905) or the account executive. Keep in mind legal advice is not offered.

CaliforniaChoice

Like last year, CalChoice is facilitating the RxDC for its employers and their plans. There is no action required from the employer. CalChoice will directly coordinate its carriers to facilitate all reporting obligations.
 

	RxDC reporting plan for CHOICE Groups
Anthem	CHOICE provided Anthem with the requested data report. No additional action is needed by CHOICE groups.
C+O	C+O did not request assistance from CHOICE. No additional action is needed by CHOICE groups.
Health Net	Health Net did not request assistance from CHOICE. No additional action is needed by CHOICE groups.
KP	CHOICE provided Kaiser Permanente with the requested data report. No additional action is needed by CHOICE groups.
Sharp	CHOICE provided Sharp with the requested data report. No additional action is needed by CHOICE groups.
Sutter	Pending Plans response
UHC	CHOICE provided UHC with the requested data report. No additional action is needed by CHOICE groups.
WHA	CHOICE provided WHA with the requested data report. No additional action is needed by CHOICE groups.

Cigna (NV)

We're awaiting specific details from Cigna (NV) on its 2023 RxDC reporting approach. We know it's important to have all the information for smooth reporting, and we're actively gathering details. We'll update this page soon.

Cigna + Oscar

We're awaiting specific details from Cigna + Oscar on its 2023 RxDC reporting approach. We know it's important to have all the information for smooth reporting, and we're actively gathering details. We'll update this page soon.

Cigna + Oscar did not request assistance from CHOICE. No additional action is needed by CHOICE groups.
 

Health Net

The Word & Brown Compliance Team reached out to Health Net to understand its 2023 CAA RxDC reporting processes. We received the following response:
 
What Health Net Is Doing

• Health Net will meet all regulatory obligations for 2023 reporting due on 06/01/2024.
• The plan will not be requesting any data from the groups to complete plan list P2 and data file D1 on behalf of their clients.
• The plan will not be issuing any type of communications to the members/groups/brokers regarding RxDC filing (confirmation of filing completion, compliance with the reporting requirements, etc.) since it is not a regulatory requirement.
• The plan will not be establishing any contracts with the groups regarding RxDC reporting since it is not a regulatory requirement.
• The group does not need to take any actions regarding the reporting or pay any fees to the plan for the reporting.

Health Net did not request assistance from CHOICE. No additional action is needed by CHOICE groups.

Kaiser Permanente

1. Will you be filing the D2 file for your fully insured clients?
   • Yes
2. Will you survey your group clients to verify employer contributions for the D1 filing?
   • Survey: Yes, groups will be emailed to complete and/or verify a form.
     • To help ensure compliance with the reporting requirements, Kaiser Permanente is reaching out to employer groups for specific information. By February 27, Kaiser Permanente will send an updated form to contract signers to request average monthly premium and Form 5500 information.
     • In the form, most groups will validate (or correct) prepopulated data and provide the following information:
       1. Form 5500 Plan Number, if applicable (ERISA plans only)
       2. Average monthly premium per member paid by Employee/Member (employee contribution)
       3. Average monthly premium per member paid by employer (employer contribution)
   • Deadline
     • March 29, 2024.
   • What happens if an employer misses the deadline?
     • Their data won’t be included.
   • Will you communicate with employers who miss the deadline? If so, how, and when?
     • No – we will not communicate with them.
3. How can employers confirm their CAA RxDC files have been filed?
   • Kaiser Permanente does not intend to share copies of submitted RxDC reporting files with fully insured groups at this time.
4. How can employers and brokers with questions about your processes contact you for more information and support?
   • Information will be included in letter.
5. For CalChoice employers: Will you request information to facilitate 2023 CAA Rx DC reporting? If so, please specify the information and deadlines.
   • Small group employers associated with Covered California for Small Business and Cal Choice do not need to complete the form as these exchanges will be providing the needed data to Kaiser Permanente.

Prominence Health (NV)

• Prominence Health has successfully submitted all required Prescription Drug Data Collection (RxDC) information on behalf of both our fully insured and self-funded groups for the 2023 reporting year.
• Based on data collected from previous years and data we solicited from select groups this year, Prominence included the average monthly premiums paid by members and by employers in the Premium and Life Years (D1) reporting. As an important point for self-funded clients, Prominence did NOT file D3-D8 (pharmacy and rebate related) reports for those groups not utilizing MedImpact as their PBM.

Sharp Health Plan

1. Will you be filing the D2 file for your fully insured clients?
   • Yes - Sharp Health Plan will be submitting all elements of the 2023 RxDC filing by the June 1, 2024 due date
2. Will you survey your group clients to verify employer contributions for the D1 filing?
   • Survey: Yes
     • RxDC Employer Reporting Intake Form
   • Deadline
     • April 19, 2024.
   • What happens if an employer misses the deadline?
     • They will need to file on their own.
   • Will you communicate with employers who miss the deadline? If so, how, and when?
     • If an employer group does not provide the information requested for the D1 Template by April 19, 2024, Sharp Health Plan will not be able to include the employer groups’ information in the Centers for Medicare & Medicaid Services (CMS) filing. In that case, the employer group will be responsible for submitting all required data directly to CMS by June 1, 2024.
   • What type of communication will you send to employers about this?
     • We will send an initial email to brokers on 3/19 and employers on 3/21 with two follow up emails.
3. How can employers confirm their CAA RxDC files have been filed?
   • If they provide information by deadline, they will be included.
4. Can employers access copies of their P2 and D1-D8 files once they have been filed?
   • No, we will submit our filing with all employer information.
5. How can employers and brokers with questions about your processes contact you for more information and support?
   • They can contact their account managers.
6. Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
   • Sharp RxDC FAQ
   • Broker Alert - What employer groups need to know about the RxDC Report
7. For CalChoice employers: Will you request information to facilitate 2023 CAA Rx DC reporting? If so, please specify the information and deadlines.
   • CHOICE provided Sharp with the requested data report. No additional action is needed by CHOICE groups.

Sutter Health Plus

1. Will you survey your group clients to verify employer contributions for the D1 filing?
   • Survey: Yes
     • For calendar year 2023 reporting, please use the online Premium Reporting Form for employers, or their brokers, to conveniently submit the required information.
   • Deadline
     • Submissions due no later than March 1, 2024.
2. How can employers and brokers with questions about your processes contact you for more information and support?
   • If you have any questions, please call Sutter Health Plus Member Services, weekdays, 8:00 a.m. to 7:00 p.m., at 855-315-5800.

UnitedHealthcare

1. Will you be filing the D2 file for your fully insured clients?
   • Yes: UnitedHealthcare will submit the P2 (group health plan), D1 (premium and life years), and D2 (spending by category), and the appropriate narratives for all customers with active coverage during the reference year.
2. Will you survey your group clients to verify employer contributions for the D1 filing?
   • Survey: Yes, through an RFI.
     • UnitedHealthcare is changing its approach to how the company collects data for the submission of pharmacy benefits and costs reporting (RxDC) on behalf of its customers. UnitedHealthcare plans to submit all files administered by UnitedHealthcare for all customers.
     • UHC will now collect the information via the employer and broker portals moving forward. UHC will not send a survey like in 2023 but will require customers to complete a Request for Information (RFI). The RFI tool opened on Feb. 14, 2024.
     • The RFI takes approximately 5-10 minutes to complete if the worksheet is prepared beforehand.
   • Deadline
     • April 10, 2024.
   • What happens if an employer misses the deadline?
     • If the RFI is not completed, UHC will submit the data in our system to CMS on or before the June 1 date. However, the submission will not be complete. The fully insured employer must submit the missing information to CMS by June 1.
   • What type of communication will you send to employers about this?
     • UnitedHealthcare sends communications through the Connect electronic newsletter to employers, brokers, and consultants regarding collection of data needed for UnitedHealthcare to submit data to CMS for the RxDC reporting requirement. It’s important to be signed up for the Connect to get RxDC and other important regulatory information. This communication explains to customers and brokers/consultants that any information not provided via the RFI in the employer/broker portal, would need to be submitted to CMS by them. UnitedHealthcare only submits data for coverage administered by UnitedHealthcare that we have in our system.
3. How can employers confirm their CAA RxDC files have been filed?
   • UnitedHealthcare will send a communication to our internal teams in mid-May 2024 to confirm that we are on track to complete the required submission to CMS. Your account team will receive a confirmation on June 6, 2024, when the submission is complete.
4. Can employers access copies of their P2 and D1-D8 files once they have been filed?
   • UnitedHealthcare does not provide copies of RxDC reports submitted to CMS.
5. Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
   • UHC CAA Pharmacy Benefits and Costs Reporting Guide 2-6-24
   • UHC CAA RxDC RFI Worksheet 2023
   • UHC CAA FAQs 12-1-23
6. How can employers and brokers with questions about your processes contact you for more information and support?
   • Contact Member Services at (800) 650-5826.
7. For CalChoice employers: Will you request information to facilitate 2023 CAA Rx DC reporting? If so, please specify the information and deadlines.
   • No - CHOICE provided UHC with the requested data report. No additional action is needed by CHOICE groups.

Western Health Advantage

1. Will you be filing the D2 file for your fully insured clients?
   • Yes 
2. Will you survey your group clients to verify employer contributions for the D1 filing?
   • Survey: Yes
     • WHA has created and sent the data survey link to employer groups on March 20, 2024.
   • Deadline
     • We are requesting the data by April 15, 2024.
3. Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
   • If you have any questions, please contact WHA’s Account Services team at 888.499.3198.
4. For CalChoice employers: Will you request information to facilitate 2023 CAA Rx DC reporting? If so, please specify the information and deadlines.
   • No - CHOICE provided WHA with the requested data report. No additional action is needed by CHOICE groups.