An Overview of the CAA RxDC Reporting Guidelines
The Consolidated Appropriations Act, 2021 (CAA) is a ruling that “established protections for consumers related to surprise billing and transparency in health care.” The CAA 2021 passed a variety of provisions, including a COVID-19 stimulus package, the Broker Compensation Disclosure, and reporting requirements for prescription drug data collection, commonly referred to as RxDC.
CMS has stated that they will use the information from RxDC reporting to:
- Identify major drivers of increases in prescription drug and healthcare spending
- Understand how prescription drug rebates impact premiums and out-of-pocket costs
- Promote transparency in prescription drug pricing
In 2024, the Centers for Medicare & Medicaid Services (CMS) released additional reporting instructions for RxDC, also known as Section 204 of the CAA 2021, in their Prescription Drug Data Collection (RxDC) Reporting Instructions report.
For additional help understanding RxDC reporting, the requirements, and the inclusions, CMS recommends:
What is RxDC reporting?
Savoy sums up this ruling as: “Under Section 204 (of Title II, Division BB) of the Consolidated Appropriations Act, 2021 (CAA), insurance companies and employer-based health plans must submit information about prescription drugs and health care spending. This data submission is called the Prescription Drug Data Collection Reporting, also referred to as RxDC Reporting.”
The RxDC report contains the following:
- Information about prescription drug plans
- Information about healthcare services spending
- Premiums paid by employers and members
What is the deadline for RxDC reporting?
CMS dictates that all RxDC reporting must be submitted by June 1st each year. Additionally, health insurance carriers must submit information about prescription drugs and healthcare spending to the following, collectively called The Departments:
- Department of Health and Human Services (HHS)
- Department of Labor (DOL)
- Department of the Treasury
Who is responsible for RxDC reporting?
In most cases, the responsibility for RxDC reporting lies on the carriers. However, your employer group clients should ensure that the carrier is filing on their behalf. This relates specifically to fully-insured group health plans. However, Savoy states that it’s “important for plan sponsors to keep any written communication from the carrier that states how they are complying with the reporting requirement on behalf of fully-insured plans.”
In the case of self-insured and level-funded group health plans, the responsibility falls more on the employer group, their benefits agent, or a third-party administrator (TPA). Again, Savoy shares that “self-insured plans may enter into a written agreement with their vendors to fulfill the reporting function on behalf of the plan; however, the plan sponsor remains liable for any failures.”
For more information, CMS laid out the following requirements for which plan types must submit an RxDC report:
| Required |
Not Required |
|
Health insurance issuers offering group market coverage
Health insurance issuers offering individual market coverage, including:
- Student health plans
- Plans sold through the Exchanges
- Plans sold outside of the Exchanges
- Individual coverage issued through an association
Fully-insured and self-funded group health plans, including:
- Group health plans subject to Employee Retirement Income Security Act of 1974 (ERISA)
- Non-federal governmental plans, such as plans sponsored by state and local government
- Church plans that are subject to the Internal Revenue Code
- Federal Employees Health Benefits (FEHB) plans
|
Account-based plans, such as health reimbursement arrangements (HRAs)
Excepted benefits include:
- Limited-scope standalone dental and vision plans
- Short-term, limited-duration insurance
- Hospital or other fixed indemnity insurance
- Disease-specific insurance
- Medicare Advantage and Part D plans
Medicaid plans
State Children’s Health Insurance Program (CHIP) plans
Basic Health Program plans
Retiree-only plans
Plans maintained outside of the U.S. primarily for the benefit of persons substantially all of whom are nonresident aliens
|
RxDC Reporting Instructions
The employer-specific data required for RxDC reporting includes:
- General plan and reporting entity identifying information
- Market segment (large group, small group, etc.)
- Average number of members covered
- State in which the plan is offered
- Average contributions paid by member
- Average premium paid by employer
- Total annual premium (or equivalent for self-funded plans)
For those responsible for submitting the RxDC report, use the Health Insurance Oversight System (HIOS) and upload the information in the Prescription Data Collection module. You must have RxDC submitter status, which can be requested from HIOS.
Using Technology to Manage Group Benefits Relationships
Although most of the responsibility for RxDC reporting lies on the carriers, it’s still essential for group benefits insurance agencies and agents to have it on their radar. Not only is it necessary for self-insured and level-funded group health plans, but it can be a key player in your agency’s client retention efforts.
Your employer groups have a lot going on, and insurance isn’t always top of mind. Taking the reins and ensuring they comply with CMS regulations can be incredibly valuable.
Using technology to manage your group benefits book of business can make a difference in building these relationships.
AgencyBloc’s AMS+ solution can help benefits agencies manage the entirety of their group benefits business in one location. Centralize all of your client’s data to make finding information, like employer group data, enrolled employees and dependents, and policy data and SBCs easier to find. Then, take notes, add Activities to track conversations, and ensure your employer group is all set for every step — even annual RxDC reporting. Upload written communications from the carriers about what they’re filing and when to the group’s contact profile to ensure you have a complete data record.
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Posted
by Allison Babberl
on Tuesday, November 5, 2024
in
Independent Insurance Agents/Agencies
- compliance management
- open enrollment
- selling
About The Author
Allison is the Content Marketing Manager at AgencyBloc. She manages the creation and schedule of all educational content for our BlocTalk and Member communities. Favorite quote: “Conversation is the bedrock of relationships. Without it, our relationships are devoid of substance.”
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