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Frequently Asked Questions

Why is there RxDC reporting?

Prescription Data Collection, or RxDC, reporting is a new annual reporting requirement under the Consolidated Appropriations Act, 2021 (CAA) aimed at increasing transparency and determining healthcare trends, particularly those related to pharmacy & medical claims, cost-sharing, and service fees.  

Who is responsible for RxDC reporting?

Employers who had or have sponsored a group health plan anytime from January 1, 2020 onward are required to have their plan information reported annually.  While carriers, TPA, and/or PBMs may offer to report or assist in reporting for the employer, the responsibility is with the employer as plan sponsor.

What is the RxDC reporting deadline?

  • The twice-delayed deadline for reference years 2020 and 2021 filing was pushed back from December 27, 2022, to January 31, 2023.  However, HIOS is still open for 2020 and 2021 filings.

  • For reference years 2022 going forward, the deadline is June 1st of the year following the preceding reference year (e.g., June 1, 2023 for reference year 2022).

 

Reporting due dates are based on the "reference year," which is defined as the calendar year immediately preceding the calendar year in which the data submissions are due (regardless of the plan year).

Does it matter whether the plan was fully insured or level-funded / self-insured? 

Not necessarily.  For employers sponsoring fully insured plans, the carriers have the vast majority of the information necessary to complete the reporting. However, they may not have gathered the contribution structures for each plan and each tier. 

For employers with an ASO, the odds are that they will have a reporting obligation for D1. Employers with carve-outs or specialty pharmacy solutions, they will likely have reporting obligations. 

My TPA/PBM is doing this for me so I'm good, right?

Not Necessarily. Carriers, TPAs, and PBMs are all handling this differently.  Contact us to help you sort it.

Are there penalties for non-compliance?

Yes. While there is "good faith" relief, that relief is limited to employers who make every effort, in good faith, to comply.  

Employers that fail to report the required data may be subject to penalties under both ERISA and the IRS Code. Governmental plans may be subject to penalties under the PHSA.

Failure to furnish the Department of Labor any requested information relating to the benefit plan results in $110 (indexed) per day - Up to $171 per day for 2022.

Will I get to see the results if my TPA/PBM files on my behalf?

No. You may be lucky to get a notice that they submitted something, but it will not detail what was submitted on your behalf.

What sets BABD Data Services apart?

Transparency sets us apart.  We provide employers with confirmations that their information was filed, what was filed, and when it was filed.  We alert employers to data that seems inaccurate and assist them in gathering the right data sets from their PBM and/or TPA.  We advocate for our employers, and we help brokers by taking the load off their shoulders. 

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