CMS UPDATES PRESCRIPTION DRUG DATA COLLECTION REPORTING RESOURCES AND TOOLS

CMS Updates Prescription Drug Data Collection Reporting Resources and Tools

On Monday, March 27, 2023, Federal regulators updated the Prescription Drug Data Collection(RxDC) Reporting Resources used to prepare and file the annual report via the HIOS Portal. Updated items include the following:

• Reporting Instructions
• Data Templates
• Drug Crosswalk
• Data Validations
• RxDC HIOS Module User manual

These resources are also found here.

CMS indicated that the most significant changes to the RxDC reporting instructions from the prior year included the following:

• Specified that RxDC reporting requirements do not apply to retiree-only plans. (Section 1.4) 
• Clarified reporting with respect to U.S. territories. (Section 1.5) 
• Added option for multiple vendors to submit the same data file on behalf of the same plan, issuer, or carrier. (Section 3.3) 
• Added option for a reporting entity to create multiple submissions in HIOS for the same reference year. (Section 3.5) 
• Rearranged plan list instructions to separately address P1, P2, and P3. (Section 4) 
• Replaced the column for HIOS Plan ID in plan list P2 with a column to collect information about benefit carve-outs. (Section 4.2) 
• Renamed columns A and B in the data files (D1 – D8) from “Issuer or TPA Name” and “Issuer or TPA EIN” to “Company Name” and “Company EIN” to reflect the fact that you may choose to aggregate data at the plan sponsor, carrier, reporting entity, or other company level, rather than only the issuer or TPA level. The purpose of these columns has not changed, only the names. (Section 5.2) 
• Renamed column C in the data files (D1 – D8) from “State” to “Aggregation State” to more clearly differentiate from the column labeled “States in which the plan is offered” in plan lists P2 and P3. The purpose of this column has not changed. (Section 5.2) 
• Extended suspension of the aggregation restriction. (Section 5.6) 
• Renamed column J in D1 from “ASO/TPA Fees Paid” to “Admin Fees Paid” to reflect that self-funded plans pay administrative fees to other types of companies, such as PBMs. The purpose of the column has not changed. (Section 6.1) 
• Specified that prescription drug rebates should be subtracted from premium equivalents in D1 regardless of whether the rebate received in the reference year is retrospective or prospective. (Section 6.1.)
• Specified that stop-loss reimbursements should be subtracted from premium equivalents in D1. (Section 6.1) 
• Specified that stop-loss reimbursements should not be subtracted from total spending in D2. (Section 7.1) 
• Specified that rebates expected but not yet received should be subtracted from total spending. (Section 7.1 for drugs covered under a medical benefit and Section 8.4 for drugs covered under a pharmacy benefit.) 
• General edits for clarity. 

The next annual RxDC report is due by June 1, 2023.