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PAI Successfully Submitted CAA RxDC Reporting

December 29, 2022

PAI successfully uploaded the 2020 and 2021 Pharmacy Benefits and Drug Costs report (RxDC) before the compliance deadline. RxDC is a provision of the Consolidated Appropriations Act (CAA) that requires group health plans and health insurance issuers to report annual data to the U.S. Departments of Health and Human Services, Labor, and Treasury (Tri-agencies) about prescription drugs and health care spending. For example, they must report employee premium amounts, drug utilization, drug rebates, and spending on health care services by type (e.g., hospital, primary care, specialty care, prescription drugs, etc.) beginning with the 2020 calendar year. RxDC is also called “RxDC reporting". “Rx” stands for prescription drug and the “DC” stands for data collection.  
More information can be found on the CMS website.

Next, PAI will be preparing for the 2022 data submission due in June 2023 once CMS issues new guidance and requirements for the next RxDC submission. We recommend you also begin organizing, tracking and preparing to report your 2022 data to us for all those required data elements that PAI does not presently track or handle (such as premium equivalent amounts paid by participants and administrative fees paid to outside  vendors/external service providers).

Groups with Carved-In Pharmacy

PAI uploads all of the required RxDC templates (P2, D1-D8, and narrative response) to CMS via the Health Insurance Oversight System (HIOS) portal. Your pharmacy benefit manager, Optum, provided us with the D3 - D8 templates to upload for you. If we administered your plan during 2020 and/or 2021, we included the information we have for your plan in the 2020 and/or 2021 RxDC reports. We also included any information you provided to us for other vendors (such as a stop loss carrier) that you contracted with separately for services that are subject to the RxDC report.  

Groups with Carved-Out Pharmacy

PAI uploads all applicable templates (P2, D1, D2 and narrative response) to CMS via the Health Insurance Oversight System (HIOS) portal. Since your pharmacy benefit manager is under a separate contract not through us, you must coordinate uploading the remaining templates (the PBM’s own P2, D3 - D8, and narrative response) through your PBM. If we administered your plan during 2020 and/or 2021, we included the information we have for your plan in the 2020 and/or 2021 RxDC reports. We also included any information you provided to us for other vendors (such as a stop loss carrier) that you contracted with separately for services that are subject to the RxDC report. Note: If you provided your PBM's name and/or any fees paid to the PBM, we included that in our D1 submission; your PBM should still submit P2, D3-D8 and narrative on your behalf.