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.
Groups must meet the following deadlines:
| Calendar Years to Report | Deadline |
| 2020 and 2021 | December 27, 2022 |
| 2022 | June 1, 2023 |
| Each subsequent calendar year | June 1 of each year |
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
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.
Carrier Responses
In this section, you'll find information about how carriers are addressing the CAA Prescription Drug Reporting requirement, as well as the employer obligations required for each carrier.
Plan Year 2022
| | |||||
|---|---|---|---|---|---|
| Carrier* | Carrier Requirement | Carrier Official Response | Employer Survey | Who is Reporting | Resources |
| Aetna | Employers must provide the following information to Aetna, which will be used to submit on behalf of the plan sponsor: • Average monthly premium paid by members • Average monthly premium paid by employer • Funding arrangement • Issuer name/legal entity | Aetna submitted all required reports for the 2022 reference year on behalf of all Small Group plan sponsors. If the plan sponsor did not complete the survey with the required premium information, then the report was released incomplete and did not include the required plan sponsor premium information. | RxDC Plan Sponsor Data Collection Form | • A plan sponsor will need to submit a form for each product based on Aetna’s legal entity. -For California HMO plans, the plan sponsor will submit a form for all their Aetna HMO plans under Aetna Health of California as their issuer/legal entity. -For non-HMO plans, the plan sponsor will submit a form for all California OAMC/PPO plans under Aetna Life Insurance Company as their issuer/legal entity. • Reminder - If a plan sponsor does not complete the form, Aetna will submit the report without the required plan sponsor data and the report will be considered incomplete. The plan sponsor will need to submit the information to CMS directly by 6/1/23. Fully Insured: Carrier Self-Funded: Carrier | Pharmacy Benefit and Drug Reporting |
| Anthem (CA) | Starting in 2023, Anthem is requiring employers to provide information on the average monthly premium paid by the member and the employer in the Premium and Life Year (D1) reporting. | Anthem is filing an aggregated response for all California Small Group (Full Insured) based on all the information we received. If a broker did not respond to the survey, their specific info would not be included in the aggregate filing. However, they’ll still be part of the filing. ( e.g. if Anthem has 10,000 groups but only get 8,500 survey responses Anthem will report for all 10,000 groups based on what they received from the 8,500.) | Fully Insured: RXDC Average Monthly Percentage and Premium Reporting Self-funded groups that want Anthem to submit their 2022 D1 reports need to complete this form with all required information no later than 3/24/2023. | Fully Insured: Carrier Self-Funded: Anthem will submit if the employer completes the form by the required deadline. | Prescription Drug Data Collection Reporting Provision Self-Funded Group Announcement |
| Anthem Blue Cross Blue Shield (CO) | Starting in 2023, Anthem is requiring employers to provide information on the average monthly premium paid by the member and the employer in the Premium and Life Year (D1) reporting. | N/A | RXDC Average Monthly Percentage and Premium Reporting Deadline for submission is 3/24/2023 | Fully Insured: Carrier Self-Funded: Pending carrier response | Broker Announcement |
| Anthem Blue Cross Blue Shield (TX) | Carrier Requirement: Please submit your average monthly premiums paid by members and the average monthly premiums paid by employer for the 2022 reference year. | N/A | Your Next Steps: 1. Log in to Blue Access for Employers or Register Here if you are new to BAE. 2. Click Prescription Drug Data Collection under Regulatory Data Collection on the BAE homepage to complete the form. 3. Enter your 2022 average monthly premiums paid by employer and members by April 13. 4. Click Submit. | Blue Cross and Blue Shield of Texas (BCBSTX) must submit reporting to the Centers for Medicare and Medicaid Services (CMS) for our fully insured customers who have prescription drug coverage. To complete this reporting requirement for those groups, we will need the account’s benefits administrator to provide us with some information. | Blue Access for Employers |
| APEX | RCI will be collecting data annually from each employer to complete the RxDC reporting. You may have submitted data in the prior year; however because information may change, we must collect data each year. | N/A | Please complete this survey by April 20. Before starting the survey, you should gather some data that will be required for the survey such as the Member and Employer Average Premium and your Health Plan name as it appears in the RCI Portal. | RCI will be submitting the files for all employers who had active coverage during the 2022 reference year. RCI is working with CitizensRx, the PBM on all Apex MEC plans, to submit the D3-D8 files. | Broker Announcement |
| Blue Shield of California | In preparation for the reports due June 1, 2023, Blue Shield is collecting and reporting D1 Premium and Life Year data on behalf of our groups and group plan sponsors. | Although the deadline for groups to submit D1 Premium information to Blue Shield has officially passed, new guidance from the Centers for Medicare and Medicaid Services (CMS) allows more leniency for fully insured groups. The new guidance allows health plans to submit total premium paid when the employee/employer premium contribution breakdown is unavailable (not submitted to BSC or is invalid). Total premium paid is information Blue Shield already has for fully insured groups. Based on this new information, Blue Shield will be submitting D1 Premium data for all small business groups, even those who did not submit D1 information to Blue Shield. We do not need the employer/employee premium percent contribution breakdown, and no action is required at this time for our small business customers. We sent communications in mid-April to fully insured employer groups who did not complete the D1 Intake Form, informing them of the new guidance. | Groups need to fill out this intake form before March 31, 2023. New reporting instruction was recently released by the Centers for Medicare and Medicaid Services (CMS). Under this new guidance, Blue Shield will submit D1 for all fully-insured groups (both groups with and without Blue Shield pharmacy benefits), even those who did not complete the D1 Intake Form. | Fully Insured: Carrier Self-Funded: click here for details | Broker Announcement CAA FAQs |
| CaliforniaChoice (CA) | Employers should refer to Carrier for specific reporting requirements. | N/A | Employers should refer to Carrier for specific reporting requirements. | Employers should refer to Carrier for specific reporting requirements. | Employers should refer to Carrier for specific reporting requirements. |
| Cigna | For the June 1, 2023 submission, which will represent the reporting year 2022, Cigna’s standard approach is to submit on our clients’ behalf. | N/A | To submit the June 1, 2023 report: Send an email to the address found in the communication sent from Cigna with the client name, account number, and average employee, versus employer percent of premium across the client’s medical, pharmacy, and behavioral coverage corresponding to their population with Cigna coverage by February 24, 2023. Include both Cigna and non-Cigna coverage. | Fully Insured: Carrier
Self-Funded: Carrier | Broker Announcement |
| Cigna + Oscar | Refer to resource announcement. | For the June 1, 2023 submission, which will represent the reporting year 2022, Cigna’s standard approach is to submit on our clients’ behalf. Employer Survey: N/A (we are filing this for our clients and don't need extra data) | Refer to resource announcement. | Fully Insured: Carrier Self-Funded: N/A | Consolidated Appropriations Act (CAA) Section 204 Medial and Pharmacy Reporting Prescription Drug and Health Care Spending Report |
| Covered California for Small Business (CA) | Employers should refer to Carrier for specific reporting requirements. | N/A | Employers should refer to Carrier for specific reporting requirements. | Fully Insured: Carrier Self-Funded: N/A | Employers should refer to Carrier for specific reporting requirements. |
| Gravie (CO Level Funded) | Pending carrier response | N/A | Pending carrier response | Pending carrier response | Broker Announcement |
| Health Net | Health Net will file the RxDC on behalf of its Commercial groups. The group does not need to report any data to Health Net. | Pending carrier response | N/A | Fully Insured: Carrier Self-Funded: N/A | N/A |
| Humana | Humana is currently working to develop a process for gathering average monthly premium paid by employers versus members for the 2022 reference year report and beyond. Fully-insured and self-funded groups will be contacted once a process is developed. | Pending carrier response | Pending carrier response | Fully Insured: Carrier Self-Funded: Carrier - see Broker Announcement for details. | Broker Announcement |
| Kaiser Permanente | Kaiser Permanente will be reaching out to fully insured employer groups to obtain the following:
| Pending carrier response | Survey Link for Employers Deadline for submission is 4/3/2023. | Fully Insured: Carrier Self-Funded: Carrier | Broker Announcement |
| Memorial Hermann Health Plan | Memorial Hermann Health Plan will be filing all required information on behalf of your employer groups. Please complete the form fillable spreadsheet no later than 4/15/2023. | N/A | Form fillable spreadsheet Deadline for submission is 4/15/2023. | Fully Insured: Carrier Self-Funded: Carrier | Broker Announcement |
| Sharp Health Plan (CA) | Per the Centers for Medicare & Medicaid Services’ instructions, Sharp Health Plan is requesting the following information from our employers to complete the D1 Template for 2022 data:
| The deadline for Employers to submit their information to Sharp was 5/1 and they are not extending this deadline. For Employers who chose not to complete the form, they will need to file directly with CMS by 6/1. Sharp has posted on their website additional resources from CMS (e.g. the reporting instruction manual) that Employers can use as guidance. | New RxDC employer reporting intake form The purpose of this intake form is to gather the required information to enable Sharp Health Plan to complete the D1 Template on your behalf. Please provide the information requested below for the 2022 calendar year and submit it by May 1, 2023. | Fully Insured: Sharp Health Plan will be submitting all elements of the 2022 RxDC filing by the June 1, 2023 due date; however, if an employer group does not provide the requested information by May 1, 2023, we will not be able to include that employer groups’ information in our filing. In that case, the employer group will be responsible for submitting all required data directly to the Centers for Medicare & Medicaid Services by June 1, 2023. Self-Funded: N/A | Broker Alert: Employers’ monthly premium data needed |
| Sutter Health Plus (CA) | Employer groups must submit information to Sutter Health Plus regarding the average monthly premiums paid on behalf of enrollees and the amount paid by enrollees each year. | N/A | Survey Link for Employers || Printable PDF Deadline for submission is 3/1/2023 | Fully Insured: Carrier Self-Funded: N/A | Broker Announcement |
| UnitedHealthcare | UHC Pharmacy Benefits and Cost Survey FAQ | Pending carrier response | Survey Link for Employers Deadline for submission was 3/10/2023. | Fully Insured: Carrier | N/A |
*Disclaimer: Please refer to carrier-specific guidelines for complete details and additional information.
Questions?
Call your Warner Pacific Sales Executive at (800) 801-2300.
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