Prescription Drug Data Collection (“RxDC”) Annual Filing Due June 1
Under the Consolidated Appropriations Act of 2021 (“CAA”), all health issuers and group health plans, both fully insured and self-insured, must submit data on prescription drug pricing and healthcare spending through the Prescription Drug Data Collection Report, known as the RxDC Report, by June 1st of each year.
What is the purpose of the report?
According to CMS, RxDC reports “are expected to enhance transparency and shed light on how prescription drugs contribute to the growth of health care spending and the cost of health coverage.”
Who Must Report?
· Group health plans offering major medical coverage, including grandfathered plans
· Prescription Drug Plans
· Wellness Benefit Plans that are integrated with major medical
Who is Exempt?
· Retiree-Only Plans
· Excepted Benefits Plans (for example, dental/vision plans)
· Short-term limited duration plans
· Account-Based Health Plans (HRA/FSA)
What must be reported?
· Basic plan information, including plan year, number of participants, states in which coverage is offered, and identification of the RxDC reporting entity.
· Average monthly premiums paid by members and employers
· Spending by Category (hospital, primary care, specialty care, medical benefit drugs, other medical costs & services)
· Drug spending (top 50 Rx by most frequent, most costly, and highest spending increase, Rx rebates and Rx spending totals.)
Who is the reporting entity?
· Fully insured plans may shift responsibility to the carrier if the carrier agrees to complete the reporting.
· Self-insured plans may delegate reporting responsibility to one or more third parties who administer the data, if those parties agree.
· Plan sponsors typically request the reporting to be completed by the TPA, PBM, and/or carrier, and multiple entities may report on behalf of the plan.
Important notes:
· Where there are multiple reporting entities, the information reported generally cannot overlap with another entity’s reported data.
· Reporting entities should work together to carefully ensure that data elements are consistent.
· Aggregation Restriction: Various data elements across multiple health plans may be combined and submitted in aggregate, for example, by aggregating the data across the reporting entity’s entire book. However, data aggregation for certain files must not be aggregated at a less granular level than the aggregation level used by the reporting entity that submitted other files. Reporting entities must work together to ensure that the data is reported in compliance with data restrictions.