Apr 03, 2024
UPDATE: Humana has extended deadline to April 19 to provide data for the Prescription Drug Data Collection requirements
Correction and resubmission needed to provide data for the Prescription Drug Data Collection requirements for Humana medical group health plans that submitted data before 2/22/2024
Notice: New survey link was sent to Humana customers between 2/28-2/29/2024.
Under the CAA, health insurers and fully-insured and self-funded (ASO) group health plans are required to report data annually regarding prescription drugs and health care spending to the Departments of Health and Human Services, Labor, and Treasury (Tri-Agencies). The Centers for Medicare & Medicaid Services (CMS) is collecting the information on behalf of the Tri-Agencies. Humana recently received updated guidance from CMS that requires additional information be collected, and any survey completed before 2/22/2024 cannot be used. A new survey link is forthcoming and will need Humana customers to complete the new survey. Humana apologizes for the inconvenience and appreciates your attention this matter.
Here's what you need to know
Prescription Drug Data Collection (RxDC) reporting for the 2023 plan year is still required to be sent to CMS no later than 6/1/2024.
Plan sponsors received a new survey form link between 2/28-2/29/2024, if Humana has an email address on file. The email notification will come from Horizon Insights and Humana request's your assistance to work with your clients to gather and provide the necessary data requirements.
For your convenience, see the new links below to the surveys as you may need to assist your clients with providing this information:
For groups that completed the survey prior to 2/22/2024, Humana will send a courtesy notice that a new survey link is forthcoming. That communication will be sent to impacted groups on 2/27/2024. Again, this notice will only be sent to groups that previously completed the survey and need to complete the new survey.
Once you and your client receive the new survey form link, please complete the information with the required data by 4/19/2024. The updated requirements for data collections now include the following:
- Group Health Plan Name
- Plan Sponsor/Employer Name and contact information
- Plan Sponsor/Employer EIN
- Plan Sponsor/Employer Principal Place of Business (Self-Funded Employers Only)
- Form 5500 number for groups that file Form 5500s. (This is a 3-digit plan number reported on the IRS Form 5500 filed with DOL. If there is more than one value, please enter them in separate boxes in the survey. This field is not required, so if you do not have a 5500 Plan Number, please skip.)
- Average monthly premium paid by members in 2023 and 2024, if applicable (Updated guidance: Calculate average monthly premium by taking total annual premium paid by members during reference year and dividing by 12. You will divide by 12 even if the coverage was not in effect for the entire calendar year.)
- Average monthly premium paid by employer in 2023 and 2024, if applicable (Updated guidance: Calculate the average monthly premium by taking the total annual premium paid on behalf of members and dividing by 12. You should divide by 12 even if the coverage was not in effect for the entire reference year.)
- Member months and life year in 2023 and 2024, if applicable (new data requirement)
For fully-insured groups only (new data requirement)
- Earned premium (All money paid by a member, policyholder, subscribers, and/or plan sponsor as a condition of the member receiving medical or pharmacy coverage)
For self-funded groups only (new data requirements)
- Admin fees paid (also included in the Premium Equivalents field)
- Premium equivalents
- Stop-loss premium paid (also included in the Premium Equivalents field)
Please refer to pages 30-34 of the CMS RxDC Report Instructions for more details on how to assist clients to calculate these data requirements.
Process for submissions that are missing or incomplete by 4/19/2024
Humana will proceed to submit the report without the required plan sponsor data. Failure to respond will impact the ability to accurately report on the plan sponsor’s behalf, and Humana will not be responsible for any liability associated with the inaccurate report.
If the data is not submitted to Humana, your clients would be required to submit the 2023 information directly to CMS by 6/1/2024 to fulfill their RxDC requirements.
If you have any questions or need more information, please view the FAQ or contact your Amwins Connect Sales Representative.
