With the first RxDC deadline fast approaching, today's "good faith relief" is a gift for which we all were waiting. Quietly announced, right before closing shop for Christmas, the tri-agencies released ACA FAQ Part 56.
Good faith is a must!
To stay off the naughty list, employers and plan sponsors must use good faith and reasonable interpretation in submitting RxDC reports for 2020 and 2021.
Grateful for a "grace period."
So long as all required files are submitted on or before January 31, 2023, the plan sponsor is deemed in compliance.
The gift of a work-around.
Asking for cooperation among TPAs and PBMs was asking for a miracle. Instead, the Departments are giving employers the benefit of the doubt, allowing duplicate submissions and relaxing the aggregation restrictions.
Employers are still responsible for ensuring all parts of the RxDC report are filed by the extended deadline of January 31, 2023.
BABD Data Services makes it easy for employers to stay compliant with our limited scope P2, D1, and D2 filing options.