I Want a New Drug…Prescription Drug Data Collection Reporting is Due December 27th

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by Becky Achten

Plan sponsors are ultimately responsible for compliance with the Prescription Drug Data Collection (RxDC) required reporting for their group health plans—and there’s no time to waste since the reporting is due by December 27, 2022. But information to complete one of the data files, the D1 (premium/cost information), may not be available to the Third Party Administrator (TPA) filing the report and, thus, may be incomplete. What’s a plan sponsor to do?

As background, the Consolidated Appropriations Act, 2021 (CAA) requires group health plans and health insurance issuers to submit certain information about health care and prescription drug spending to the Department of Health and Human Services, Department of Labor, and Department of the Treasury (collectively, the Departments) annually. The reporting consists of a plan identifier file, eight separate data files, and a narrative response.

Guidance specifically permits multiple vendors to submit the data files on behalf of group health plan sponsors, but multiples of the same type of data file should not be submitted. However, many TPAs have stated—even though they may not have all the required data for a complete D1 data file—that they will not intake and combine data from other vendors or employers in completing the respective data files this year. The Departments, understanding that data collection may be challenging, have issued some relief in that they will not take enforcement action against the plan sponsor if the average monthly premium paid by employers and employees (Columns E and F) is not included on the D1 for the 2020 and 2021 reporting period, as long as the information is provided for 2022 and beyond.

However, no such relief exists for reporting the premium equivalent (Column I). As this is the total cost of providing the health benefits, a plan sponsor with carved-out benefits will likely need to provide this data. If the TPA will not intake the data, the D1 filed by the TPA will be incomplete.

Although data files are not to be duplicated, plan sponsors risk non-compliance by having data files submitted that are not complete. Therefore, plan sponsors may want to consider filing a complete and compliant D1 if their TPA files will have missing data other than those granted relief. If doing so, keep in mind the following:

  • It can take up to two weeks to get an account established on the HIOS system. Don’t wait until the last minute to start the process if you haven’t already!
  • The HIOS system will not prevent a plan sponsor from filing a duplicate D1 in addition to a TPA filing. Plan sponsors may want to consider uploading a supplemental document (PDF or Word) to explain that a duplicate D1 has been submitted by the plan sponsor to ensure complete and accurate data was filed for the reporting period.
  • Every data file must be accompanied by a P2 report. This report includes the plan identification information. Column B is a unique group health plan number that will tie together the data files submitted by multiple vendors for a plan. Any number can be used, but the same number must be used by all vendors submitting on behalf of the same plan.
  • On the other hand, multiple reporting entities may upload different narrative responses on behalf of the plan. Confirm with the plan vendors what narrative items are being submitted, and be prepared to supplement the information.
  • The current HIOS system has no mechanism whereby plan sponsors can confirm the reporting completed by vendors. Since plan sponsors remain fully responsible for compliance, consider getting specific written agreements and confirmations from vendors regarding the reporting.

Once plan sponsors complete this year’s filing, they should begin working on the filing for the 2022 data, due June 1, 2023. The good faith relief on the D1 for certain items does not apply to the 2022 filing, so plan sponsors should work with their TPAs to provide a unified approach for complete filing and to update service agreements to specify which data elements the TPA will be responsible for submitting on behalf of the plan.