What am I looking forward to this holiday season?
If you guessed required disclosures and detailed information about employer sponsored plan spend, trends, and (my favorite) direct and indirect renumeration retained by Carriers, TPAs, and PBMs give yourself a pat on the back!
The CAA really is the gift that keeps on giving - and this year it is in the form of the Prescription Drug Data Collection (RxDC) filings due December 27, 2022. There is much more than just Rx data in store for us - here is some high level information for you!
Who has to file the RxDC data? The obligation falls on all ERISA plans and other group health plans (importantly, no exception for church plans or non- federal governmental plans). While much of the data will come from the TPAs and PBMs, it is ultimately the responsibility of the employer plan sponsor to ensure that the data files are submitted timely and in the manner set forth in the rule.
What is in the files? Again, while it is called the Rx data collection, it includes SO much more. Premium information, ASO fees, stop loss fees, total health care spending broken down by type of cost ... the list goes on.
Medical spend data will be captured on file D2 and includes information on primary care spend, hospital inpatient and outpatient, capitated payments, and medical drugs (among others). These items are detailed on pages 23-30 of the CMS RxDC Reference Guide.*
Rx data, which will be mostly filled by PBMs, include the top 50 most prescribed drugs, top 50 that have increased in cost and top 50 by cost and a lot of information about rebates.
Notably, the instructions for file D6 include details on how to disclose the "PBM Spread." (see link to detailed RxDC instructions located at the bottom of the page).
The idea behind this massive data collection effort is that sunshine is the best disinfectant - if we know the price, perhaps someday we can pay less.
I hope to enjoy some sunshine this holiday season... just not the kind you get in Florida. #healthcare
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