CMS Releases 2022 RxDC Reporting Instructions

CMS recently released the Prescription Drug Data Collection Reporting Instructions for the 2022 calendar year (the 2022 RxDC instructions). The 2022 RxDC instructions reflect numerous changes from the prior year’s instructions.

Under the CAA, Section 204, fully insured and self-insured group health plans and insurers are required to report certain prescription drug and healthcare spending data to CMS. The data must be submitted to CMS’s Health Insurance Oversight System in specified files and formats.

The 2020 and 2021 calendar year data submissions were due by December 27, 2022. The 2022 calendar year data must be submitted by June 1, 2023.

Key updates to the 2022 RxDC instructions include, but are not limited to:

• Specification that RxDC reporting does not apply to retiree-only plans (Section 1.4).
• Clarification that RxDC reporting applies to Washington, DC and the US territories (Section 1.5).
• Addition of an option to allow multiple vendors to submit the same data file on behalf of the same plan (Section 3.3). This option may apply if a plan has multiple vendors that will not work together or changes a vendor (e.g., a TPA or PBM) during the calendar year.
• Replacement of a column in the plan list (P2) information to allow for the collection of information about “benefit carve-outs,” defined as benefits administered, offered, or insured by an entity other than the entity that administers, offers, or insures most of the plan’s other benefits (Section 4.2).
• Several clarifications regarding the impact of prescription drug rebates and stop-loss premium reimbursements on the determination of the premium equivalent and total spending (Sections 6.1 and 7.1).

The 2022 RxDC instructions also reference additional resources available to assist group health plans and insurers with the reporting process.

Group health plan sponsors should be aware of the updated instructions and work closely with their insurers, TPAs, PBMs and other vendors, as applicable, to ensure the 2022 required data is timely and accurately submitted by the June 1, 2023, deadline.

2022 RxDC Instructions »