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CAA 2023 Prescription Drug Data Collection (RXDC) Carrier Reference

| Source: Word & Brown , by Jonathan Close

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
We’re awaiting specific details from Aetna 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.

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
      • We are emailing fully insured Large Group and Small Group commercial clients, as well as clients with Minimum Premium, MEWA, and Anthem Balanced Funding plans on the week of February 12, 2023. The email includes a link to an online form for these clients to provide the information we need to complete the filings on their behalf.
  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?

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.
  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?
  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.

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.

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.

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.
      • Fully insured group contract signers across the enterprise were sent an email from Kaiser-Permanente-RxDC@dp.org on February 1. This email includes a link to a form, specific to that group business, for them to complete.
      • 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 15, 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.

Sharp Health Plan

  1. Will you be filing the D2 file for your fully insured clients?
    • Yes – we will follow the same process as last year.
  2. Will you survey your group clients to verify employer contributions for the D1 filing?
    • Survey: Yes
      • Not yet available.
    • Deadline
      • Not yet available.
    • 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?
      • We plan to begin our outreach in mid-March to Employers, in an effort to obtain the information. If Employers do not submit their information by deadline, they will be excluded from filing.
    • What type of communication will you send to employers about this?
      • We will send an initial email 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.

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?
  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.

Western Health Advantage
We’re awaiting specific details from Western Health Advantage 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.

 

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