Aug 19, 2022
Question: I’ve heard that the prescription drug reporting requirement under the transparency rules was delayed. Does this mean I don’t need to worry about any impending requirements?
Answer:
There are two separate requirements to pay attention to under the Transparency in Coverage (TiC) final rule with respect to prescription drugs:
1. Prescription Drug & Health Cost Reporting. TiC final rule requires health plans (including grandfathered plans) and health insurance carriers to disclose certain coverage and pricing information related to prescription drug and other health care spending. The first such report is due by December 27, 2022. Subsequent reports are due annually by June 1.
2. Machine-Readable Data Files. The TiC final rule also requires carriers and non-grandfathered health plans to publicly disclose machine-readable files detailing:
- In-network provider rates for covered items and services;
- Out-of-network allowed amounts for covered items and services; and
- Historical prices for covered prescription drugs.
The due date for posting MRFs for the first two items (in-network provider rates and out-of-network allowed amounts) was July 1, 2022. However, the third requirement related to posting prescription drug data has been delayed pending additional guidance.
Therefore, there are two separate prescription drug requirements and associated due dates to pay attention to. One due date is approaching at the end of December. The other is currently on hold, pending further guidance.
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