What is prescription-drug reporting, and how does it affect you and your groups? Get the answers to these questions, and more, in this resource page.
What is Rx reporting?
Prescription-drug reporting is a federal mandate created by the Consolidated Appropriations Act of 2021, which was signed into law in December 2020. It requires insurance companies and group health plans to report prescription drug data to the government.
Why is the government doing this?
For years, prescription costs for drugs has been a hot topic. The federal government wants to use the data that will be reported to study the prescription drug industry; consider legislative or regulatory changes; and look at market concentration (i.e., essentially antitrust issues).
How does this affect agents and groups?
Insurance companies have sent a lot of questions and communications to groups about drug reporting. Some groups may not understand why this is happening. That’s where you come in: You can help guide your groups and facilitate the reporting process so they can meet their deadline.
Important things to note
Whether your group is fully insured or self-funded, they have to comply with this mandate.
Resources
Here are some important resources you can reference, including links to detailed break-downs:
- News announcement
- Warner Pacific webinar with expert and attorney Marilyn Monahan
- Marilyn Monahan Presentation: Quick Links
- Departments of Labor, Health and Human Services, and the Treasury
- Centers for Medicare & Medicaid Services
Information about how carriers are addressing the CAA Prescription Drug Reporting requirement, as well as the employer obligations required for each carrier are listed below. We are making updates to this list, please check back frequently for most current information.
CARRIER* | EMPLOYER SURVEY | WHO IS REPORTING Fully Insured | WHO IS REPORTING Self/Level Funded/ASO | RESOURCES |
Aetna | Employers will receive an email from Aetna, requiring the following data:
| Carrier will report | Small Group Updates | |
Anthem (CA) Anthem Blue Cross Blue Shield (CO) | Fully Insured Form Please submit by March 15, 2024. | The week of February 12 – Fully Insured clients Carrier will email Fully Insured National Account, Large Group, and Small Group commercial clients, as well as clients with Minimum Premium, MEWA, and Anthem Balanced Funding plans. The email will include a link to an online form for these clients to provide the information we need to complete the filings on their behalf. Anthem is filing an aggregated response for all California Small Group (Full Insured) based on all the information they received. If a broker did not respond to the survey, their specific info would not be included in the aggregate filing. | The week of February 12 – ASO client D1 opt-in Carrier will email ASO Large Group and National Account clients, and provide a link for them to request that we file their 2023 D1 Premium and Life Years report. For those who opt in, we will submit the aggregated data by market segment on their behalf for the benefits we administer and maintain. Groups that want Anthem to submit their 2022 D1 reports need to complete the survey with all required information no later than 3/15/2024. | |
Anthem Blue Cross Blue Shield (TX) | Pending 2024 | Carrier will report | Blue Access for Employers RxDC Reporting Announcement | |
Apex | Please go to the CAA RxDC Survey by clicking here. Please complete the survey by the April 20th deadline | Carrier will report | Carrier will report | RxDC Reporting Announcement |
AvMED | Pending 2024 | Carrier will report | ||
Blue Shield of California | Upon logging in, active groups will need to fill out the intake form available via a banner on Employer Connection. Covered CA Small Business groups, whether active or inactive with Blue Shield, will need to fill out this intake form, using the group ID and following web key: #24yr23. Survey deadline is April 5, 2024. However, if additional time is needed, late responses will only be accepted until April 19, 2024. | Carrier will report Please view the D1 Intake FAQs | Refer to submission grid | Broker Alert Broker Announcement CAA FAQs |
CaliforniaChoice | Please refer to Carrier Responses. | Carrier Responses | N/A | |
Cigna | No survey announced | Carrier will report | Carrier will report | CAA Provision 204 Prescription Drug & Health Care Spending Report Fact Sheet |
Cigna + Oscar | No survey announced | Carrier will report | N/A | |
Community Care Health | Employer groups have been notified to provide the 2023 employer and employee contributions for the 2024 RxDC reporting. Due by March 15, 2024. | Carrier will report | N/A | |
Covered California for Small Business | Please refer to enrolled carrier. | N/A | Consolidated Appropriations Act, Section 204 Pharmacy Reporting | |
Gravie (CO Level Funded) | Pending 2024 | |||
Health Net | No survey required | Carrier will report | N/A | Broker Announcement |
Humana | Online survey sent to health plan sponsors | Carrier will report | (CAA) Prescription Drug Data Collection (RxDC) | |
Kaiser Permanente | Employer groups must provide the following information:
Kaiser Permanente will send form from Kaiser-PermanenteRxDC@kp.org to contract signers to request this information. The form must be completed by March 29, 2024. Small group employers associated with Covered California for Small Business and Cal Choice do not need to complete the form as these exchanges will be providing the needed data to Kaiser Permanente. | Carrier will report | Carrier will report | Broker Announcement account.kp.org User Guide |
Sharp Health Plan (CA) | RxDC Employer Reporting Intake Form Please provide information by April 19, 2024. | Carrier will report | N/A | Employer Alert
|
Sutter Health Plus (CA) | Premium Reporting Form due date no later than March 1, 2024 | Carrier will report | N/A | |
UnitedHealthcare | To access the RFI tool, the employer must go to the employer portal beginning February 14, 2024. The RFI must be completed by the April 10, 2024, deadline. | 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).
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 D3-D8. | UnitedHealthcare submits all data and appropriate narratives for plans administered by UnitedHealthcare and OptumRx carve-in (integrated). There is no fee for clients who follow the standard approach. • UnitedHealthcare will submit the P2 (Group Health Plan list), D1 (Premium and Life Years), and D2 (Spending by Category) files for all clients who had coverage in the 2023 reference year. • For clients with OptumRx integrated PBM, UnitedHealthcare will also submit the D3-D8 files. | Broker Announcement CAA FAQs |
Western Health Advantage | Pending 2024 | Carrier will report | N/A |
*Disclaimer: Please refer to carrier-specific guidelines for complete details and additional information.
Employer Group Responsibilities for Late Carrier Submissions
If the carrier submission deadline has passed and the required information has not been submitted, employer groups may be responsible for providing the survey data directly to CMS. In most cases, this will involve submitting the P2 and D1 files to CMS by June 1. To determine the average premium paid by the employee and employer, refer to the CMS Instruction Guide (pages 21-22), which outlines the calculation process. The average premium amount paid by a member includes both the employee and their dependents.
Important Notice: To ensure a smooth filing process, it is highly recommended that employers register on the website well in advance of the submission deadline. Keep in mind that registration verification may take several weeks. Disregarding the survey from the insurance carrier could result in the employer being held accountable for any delays or incomplete submissions.
For assistance with the submission process, visit the CMS Survey page. Additional information about RxDC reporting can be found on the CMS website. To stay updated on announcements and register for training webinars, visit the Registration for Technical Assistance Portal (REGTAP). If you can't find the answer to your question in REGTAP, contact the help desk at 1-855-267-1515 or email them. Include "RxDC" in the body of the email for faster service. Responses are typically provided within the same day, with a full resolution expected within 1-2 weeks.
Annual reporting schedule
Reports are due annually on June 1st.
Questions?
Call your Warner Pacific Sales Executive at (800) 801-2300.