BRMS remains committed to keeping you in the loop on the latest industry developments as they happen. There are some important changes coming in the next month via the Consolidated Appropriations Act and its Prescription Drug Data Collection program that will take effect on December 27, 2022. Here are the key pieces of information you should be aware of and what we’re doing at BRMS to ensure your compliance:
Consolidated Appropriations Act (CAA) Prescription Drug Data Collection (RxDC)
What is it?
With the passing of the Consolidated Appropriations Act (CAA), group health plans and health insurance issuers offering group or individual health insurance coverage are now required to submit information about prescription drugs and health care spending to the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury. The government refers to this as “Prescription Drug Data Collection (RxDC).”
What is BRMS doing?
- Contacting PBM vendors to identify what they will be providing for this requirement,
- Determining if we will be uploading data files to CMS, who is collecting the data on the government’s behalf.
- Uncovering whether there is an associated cost involved.
The answer can be different for each PBM and each group. The tracking and coordination of who is doing what has become difficult, and the situation is changing as we get in touch with each vendor and group.
We are happy to assist in producing and submitting the appropriate files on a group-by-group basis. However, we have not received responses from all our PBM vendors, so there are still some unknowns currently.
BRMS is also working through the registration process so we can submit data files to CMS and review file layouts to understand exactly what data we need. Our objective is to develop and produce the required data files.
When is it due?
The first report is due on December 27, 2022, for the 2020 and 2021 calendar years.
Future annual reports will be due on June 1 for the prior year.
2022 data will be due on June 1, 2023.
What can Employers do?
Touch base with your BRMS Account Executive or Client Manager to let us know of any plans you may already have in place with your PBM vendor so that we can coordinate.
Data Files
| Subject | Plan Lists | Data Files |
| File Names | P stands for Plan
· P1: Individual and student market plan list · P2: Group health plan list · P3: FEHB plan list |
D stands for Data
· D1: Premium and Life-Years · D2: Spending by Category · D3: Top 50 Most Frequent Brand Drugs · D4: Top 50 Most Costly Drugs · D5: Top 50 Drugs by Spending Increase · D6: Rx Totals · D7: Rx Rebates by Therapeutic Class · D8: Rx Rebates for the Top 25 Drugs |
| Purpose | The plan lists identify the plans in a submission. The plan lists also collect plan-level information required by statute, such as the beginning and end dates of the plan year, the number of members, and the states in which the plan or coverage is offered. | The data files collect premium and spending information at an aggregate level. |
| Requirement | · P1 is required for plans in the individual or student market
· P2 is required for employer-based health plans that are not FEHB plans · P3 is required for FEHB plans |
All 8 data files required. |
| File Format | Comma Separated Values (CSV) | Comma Separated Values (CSV) |