Feb 07, 2024
IMPORTANT UPDATE:
Due to technical issues on their end and updated guidance from CMS about the 2024 submission, these below dates have changed as follows:
- The opening of the RFI tool has been moved from Thursday, February 1, 2024, to Friday, February 16, 2024.
- The deadline for employers/brokers to complete submissions (or to contact UHC to request data) has been moved from Sunday, March 31, 2024, to Wednesday, April 10, 2024. Note that this deadline remains firm.
All other information below remains the same.
UnitedHealthcare will complete the CAA Prescription Drug (RxDC) reporting for its fully insured and self-funded/level funded groups, including those with OptumRx as the integrated PBM. However, groups with these will need to complete the Request for Information (RFI) tool for RxDC reporting between February 1, 2024, and March 31, 2024. The March 31, 2024, deadline is firm.
Under the Consolidated Appropriations Act (CAA), health insurers offering group or individual health coverage and self-funded 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). June 1, 2024, is the required submission date to report 2023 data through a web portal set up by the Centers for Medicare & Medicaid Services (CMS).
To support its customers with this important filing, UnitedHealthcare will be submitting the P2 (Group Health Plan), D1 (Premium and Life Years) and D2 (Spending by Category) files for all employers who had active coverage during the reference year (2023). However, completion of the submission requires gathering some information not currently maintained in their system.
UnitedHealthcare will also submit the D3-D8 data files for customers with OptumRx as an integrated PBM. UnitedHealthcare has access to all data required to complete the submission of the D3-D8 data files. Customers who use any other PBM, including OptumRx Direct, must work with that PBM to submit the D3-D8 files.
Going forward, UnitedHealthcare will collect P2/D1 data annually via the Request for Information (RFI) in the Employer Portal or by emailed survey. A worksheet is available for customers to use when gathering RFI information for 2023; this worksheet will making the keying of data in the RFI easier. UnitedHealthcare has also prepared a training video that customers can use when completing the worksheet and tool.
If the RFI or survey is not completed and received by March 31, 2024, UnitedHealthcare will submit the limited data in their system to CMS on or before the June 1, 2024, due date. However, the submission will not be complete. Data elements not provided to UnitedHealthcare will need to be submitted to CMS by the health plan or another reporting entity. The health plan accepts any risk arising from the health plan’s failure to provide any requested information to UnitedHealthcare for reporting.
Note: self-funded customers wishing to have UnitedHealthcare provide data to them and who will take responsibility to submit all data to CMS themselves, must contact their Amwins Connect Regional Sales Manager no later than March 31, 2024.
For questions or more assistance, contact your Amwins Connect Regional Sales Manager.
