QUESTION: We’ve heard there’s a requirement to report prescription drug and well being care spending to the federal government in 2022. What are the reporting necessities and when are the stories due?
ANSWER: 12 months-end laws handed in 2020 requires group well being plans and insurers to yearly report prescription drug and well being care spending, premiums, and enrollment data to the federal government (see our Checkpoint article). Along with normal figuring out data equivalent to the start and finish dates of the plan 12 months, the variety of enrollees lined, and every state wherein the plan is obtainable, a broad vary of well being care spending data have to be reported (see our Checkpoint article). For instance, the typical month-to-month premium paid by staff versus employers have to be reported, in addition to the whole well being care spending damaged down by sort (equivalent to hospital care, main care, and specialty care) and prescription drug spending by enrollees versus plans and insurers. Plans and insurers should additionally report the 50 most steadily disbursed model pharmaceuticals, the 50 costliest pharmaceuticals by whole annual spending, and the 50 pharmaceuticals with the best improve in plan or protection expenditures from the earlier 12 months.
Info have to be submitted based mostly on the “reference 12 months,” which the companies have outlined because the calendar 12 months instantly previous the calendar 12 months wherein the information submission is due. Calendar 12 months 2020 data was initially required to be submitted by December 27, 2021; calendar 12 months 2021 data by June 1, 2022; calendar 12 months 2022 data by June 1, 2023; and so forth. Nevertheless, the companies have suggested that they won’t provoke enforcement actions towards plans or insurers that submit the required knowledge for the 2020 and 2021 reference years by December 27, 2022. The companies have indicated that the information is to be submitted by means of the RxDC module within the Well being Insurance coverage Oversight System (HIOS) (see our Checkpoint article).
For extra data, see EBIA’s Well being Care Reform guide at Part XXXVI.L (“Prescription Drug and Well being Care Spending Reporting”). See additionally EBIA’s Self-Insured Well being Plans guide at Part XXIX.D.4 (“Prescription Drug and Well being Care Spending”) and EBIA’s ERISA guide at Part XXI.C (“Warning Relating to Further Obligations”).
Contributing Editors: EBIA Workers.
