Last month, brokers and groups received an email communication stating they would be responsible for submitting D1 Premium and Life year data (D1) to the Centers for Medicare and Medicaid Services (CMS) for reports due by June 1, 2023.
After evaluating broker and group feedback, the project team and stakeholders have reconsidered this approach. A new option for collecting and reporting D1 information on behalf of fully-insured groups and self-funded ASO group plan sponsors will be rolled out. You can view reporting responsibilities here.
A communication to group plan sponsors is being sent by Blue Shield.
Employer Survey Required by March 16th
In preparation for the CAA Sec 204 Pharmacy Drug Cost reports due June 1, 2023, Blue Shield is collecting and report D1 Premium and Life Year data on behalf of their groups and group plan sponsors according to their reporting responsibilities grid.
Groups will need to fill out this intake form before March 17, 2023. Group plans who miss this deadline will not be included in Blue Shield's filing and may be subject to non-compliance if they do not then report the required data directly to the CMS on their own.
Please view the D1 Intake FAQs for more information.
Be sure to visit the Blue Shield Consolidated Appropriations Act and Transparency in Coverage Final Rule page for information on how Blue Shield is complying with all mandates.