Under the CAA, Section 204, insured and self-insured group health plans are required to report significant information regarding prescription drug and healthcare spending to the government. The 2020 and 2021 calendar year data submissions are due by December 27, 2022. However, under recently announced relief, a submission grace period is available to employers who make a good faith submission of the 2020 and 2021 data on or before January 31, 2023.
The data must be submitted to the Health Insurance Oversight System (HIOS) in files and formats specified by CMS. As applicable, employers should work closely with their carriers, third-party administrators, pharmacy benefit managers and other vendors to ensure the required information is timely and accurately provided. In some cases, employers that sponsor self-insured plans may need to submit data directly to HIOS.
Detailed information regarding the reporting requirements, including instructions, FAQs and a HIOS portal user guide, is available on the CMS website.
Employers should also keep in mind that the reporting of 2022 data is due by June 1, 2023. Employers should respond timely to any requests from carriers and service providers for necessary data, such as the average monthly premium paid by employers and employees. Employers should confirm in writing that the carrier or service provider will submit the June filing for the plan.
PPI Benefit Solutions does not provide legal or tax advice. Compliance, regulatory and related content is for general informational purposes and is not guaranteed to be accurate or complete. You should consult an attorney or tax professional regarding the application or potential implications of laws, regulations or policies to your specific circumstances.
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