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Drug Cost Reporting Compliance

Starting in 2022, the CAA required employer-sponsored health plans, health insurance issuers, and PBMs to report annually on prescription drug and healthcare spending by June 1st each year.

This means plan sponsors must report for the 2023 calendar year by June 1, 2024.

Plan sponsors must have reported for calendar years 2020 and 2021 no later than Jan 31st 2023 under an extended timeline.

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Compliance Requirements

In December of 2020 Congress passed into law the Consolidated Appropriations Act (CAA of 2021).  As a portion of this bill, Insurers and Plans must submit cost data on pharmacy benefits and drug costs annually.  The stated intent of this reporting is to ensure the departments have sufficient information regarding prescription drugs to fully understand where plan assets are being spent.

Unfortunately as you dig into this requirement you quickly find that the reporting requires not only prescription drug spend data but also items that the TPA doesn’t has, such as employee contribution and full descriptions of wellness and disease management programs offered at the plan sponsor level.

The data reporting requirement includes each plan’s 50 most costly drugs, the 50 drugs with the greatest increase in plan expenditures over the prior year, total spending on health care services (broken down into some detail), average monthly premiums, and any impact on premiums from rebates, fees, or other remuneration paid by drug manufacturers. 

The reporting must be made on an annual basis calculating claim spend for all claims incurred for days of the calendar year that were paid by the plan by the last day of the March the following year.  

Plan sponsors must report for the 2023 calendar year by June 1st 2024.