Originally published as Most Employers Work with Partners to Reach CAA Compliance Before December Deadline on December 21, 2022 | Updated on January 6, 2023
On both state and federal levels, 2022 was a busy year for the legal experts in the pharmacy benefits industry. Collecting information was a large element of 2022 as the first reporting deadline for the Section 204 requirement of the Consolidated Appropriations Act of 2021, also called “RxDC reporting,” approached.
On December 23, the Centers for Medicare and Medicaid Services (CMS), U.S. Departments of Labor, Health and Human Services, and the Department of the Treasury published an FAQ that provided an extension to the CAA-21 Section 204 RxDC filing period for 2020 and 2021 prescription drug and healthcare spending reporting. The deadline has been extended from December 27, 2022, to January 31, 2023. Optum, Caremark, and Express Scripts have finalized their submission files and confirmed that all submissions would be completed before January 31, 2023, if not already filed.
The information on prescription and health care spending, the drugs that account for the most spending, which medications are prescribed most frequently, rebates from manufacturers, and premiums and cost-sharing for members will be shared with several federal agencies. The goal of the RxDC data is to help identify the major drivers of increased prescription drug and healthcare spending, measure how rebates impact premiums and out-of-pocket costs, and promote transparency on drug pricing.
While plan sponsors can submit the information on their own, PBMs, issuers, TPAs, and other third-party vendors can also step in and assist with the submission. Most of our clients chose to work with the PBM or a trusted partner to submit the information on spending, prescription costs and frequency, rebates, premiums, and cost-sharing on their behalf.
In the future, this will become an annual requirement with a deadline each June. In our latest webinar, I covered this topic as a top takeaway from 2022 because our team worked closely with so many to meet the deadline, and we’ll be supporting you and your clients in the years to come with an eye out for any change or ways to make the process easier.