May 19, 2023
Update on Employer Responsibilities for the Upcoming RxDC Reporting due June 1, 2023
May 2023
Many employers received an email from their carrier or TPA (for Self-Insured plans) requesting that the employer provide member and cost data so that the vendor could submit RxDC reporting on the employer’s behalf. What’s going on?
The RxDC reporting requirements contain data elements that the carrier or TPA may not know because they do not have the information. The one data element creating the biggest problem is Employer/Employee Plan Contributions.
Regulators extended temporary relief for the Dec. 27 reporting deadline (until January 1, 2023) so that employer/employee plan contribution reporting was optional.
- This relief was not extended to the deadline for 2022 RxDC reporting which is due no later than June 1, 2023.
Consequently, vendors who are reporting on the behalf of the employer’s plan are asking for this information from employers.
Many employers, especially those with fully insured plans, did not have to do anything during Round 1. The carrier or TPA handled all of the reporting for the employer.
That will not be the case in Round 2. Every employer will likely have some role to play in completing Round 2 reporting.
Reporting consists of 9 spreadsheets submitted through CMS HIOS System
| D1 | Plan Details (vendors, # covered individuals, premiums, etc.) |
| D2 | Medical spending information |
| D3-D8 | Drug spending information |
| P2 | Plan Identifying information - sort of a cover sheet that identifies which plans are included in the accompanying D files |
The D1 File – Contains general information about the employer’s plan
| COLUMN | INFORMATION REQUIRED |
|---|---|
| A | Company Name |
| B | Company EIN |
| C | Aggregation State |
| D | Market Segment |
| E | Average Monthly Premium Paid by Members |
| F | Average Monthly Premium Paid by Employers |
| G | Life Years |
| H | Earned Premium |
| I | Premium Equivalents |
| J | ASO/TPA Fees Paid (included in the Premium Equivalents field) |
| K | Stop Los Premium Paid (included in the Premium Equivalents field) |
How did Carriers and TPAs Respond?
Some carriers required employers to report Average Monthly Premium data to them through online form, email, or paper form:
- e.g: UHC requesting premium and other D1 data be submitted via online portal no later than March 3, 2023.
- If employer did not respond in time UHC would submit D1 without the premium information.
Some carriers/TPAs will no longer file D1 and employer will have to submit a P2 and D1 file on their own:
- e.g: Blue Shield of California indicated employers will have to submit D1 files on their own going forward. Then they backed down and said they would submit without the premium information included for that employer.
- Other vendors are saying that if employer did not provide the requested data by their deadline they will not file a D1 for them.
How will CMS Know if Employer Plan Data is Complete?
P2 File – this data will be submitted for each employer plan included in the vendors aggregate data.
| Group Health Plan |
| Group Health Plan Number |
| Care-out Description |
| Form 5500 Plan Number |
| States in which the plan is offered |
| Market Segment |
| Plan Year Beginning Date |
| Plan Year End Date |
| Members as of December 31 of the reference year |
| Plan Sponsor Name |
| Plan Sponsor EIN |
| Issuer Name |
| Issuer EIN |
| TPA Name |
| TPA EIN |
| PBM Name |
| PBM EIN |
| Included in D1 Premium and Life Years? If the vendor is not submitting a D1 file for the plan they will answer No in this field. |
Reporting Process Details
- Vendors will submit aggregate data and it will not employer plan specific. So, employer’s plan contribution rates will be “averaged” with all other employer contribution rates – not reported on an employer-by-employer basis.
- But the vendor will submit a P2 file that lists all of the employers and plans included in their aggregate data.
How will CMS Know if Employer Plan Data is Complete?
If vendor did not submit any D1 data for the employer, then the employer should set up a HIOS Account and submit their own D1 File:
- Employer will also need to submit a P2 along with the D1.
- CMS allowed email submission of D1 file for December 27 deadline – this is not an option this time.
HIOS Portal Set-up:
- This takes time to get the account approved.
- It will also ask for a lot of personal information for security purposes.
It is very important that employer group health plans contact their carriers, TPAs (for Self-Insured plans), and/or PBMs for clarification to find out exactly what they will or will not be submitting. June 1, 2023 is fast approaching!
Amwins Connect Resource Page for Prescription Drug Data Collection (RxDC)
CMS Prescription Drug Data Collection (RxDC) Reporting Instructions updated March 3, 2023
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