The deadline for the second annual Prescription Drug Coverage Reporting Form (RxDC Report) is this June 1, 2023, and will continue to be required annually on the first of June. This report mandates that group health plans and health insurance issuers report information on prescription drugs and health care spending to the Departments of Labor, Health and Human Services, and Treasury. This reporting requirement applies to both grandfathered and non-grandfathered group health plans and health insurance issuers in the individual and group markets. Although the first report deadline passed in late December, the second report deadline is quickly approaching, and compliance with the reporting requirements is essential to avoid potential enforcement action rumored to be a $100 per day penalty.
Although employers can submit these reports on their own, the Departments expect that most employers will use issuers, third-party administrators (TPAs), pharmacy benefit managers (PBMs) or other third parties to submit the RxDC reports on their behalf and satisfy these new reporting obligations. To do this, a plan or issuer must enter into a written agreement with the third party providing the information on its behalf in accordance with the interim final rules.
To ensure your business is compliant and will be able to meet the upcoming deadline, employers should ensure their TPAs or PBMs are compliant with this requirement, confirm that their issuers will submit the RxDC reports, and update their written agreements with these third parties to reflect this reporting responsibility. This is especially important because in most cases outlined by the interim final rules, the issuer (not the plan) is found to be the party that violates the reporting requirements upon failed submission of the required information.
To learn more about the RxDC report, reach out to an agent at Diversified or visit: https://www.thehortongroup.com/resources/prescription-drug-data-collection-rxdc-reporting/.
DII is your partner in workplace compliance and understanding business requirements. Our team of experts can work with you to understand how to update your policies and make sure you meet all reporting deadlines. Please contact your DII representative for more information. #RxDC #Reporting #NSA #PrescriptionDrugs
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