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Plan sponsors must report for calendar years 2020 and 2021 no later than December 27th, 2022.
Plan sponsors must also report for the 2022 calendar year by June 1st , 2023
Plan sponsors must report for calendar years 2020 and 2021 no later than December 27th, 2022.
Plan sponsors must also report for the 2022 calendar year by June 1st , 2023
For those brokers who have fully explored the new Drug Cost Reporting Requirements, you are likely aware that this effort will require coordination between your Plan Sponsor Clients, their TPA(s), and their PBM(s). Why are so many parties involved? PBMs lack the data necessary to complete the plan level files as well as data files 1 & 2. Further, TPAs also lack data necessary to complete their end of the reporting.
This creates a precarious situation for brokers as the marketplace is under the impression that ‘PBMs have it covered‘ since after all this is supposed to be Drug Cost reporting. Unfortunately, too often this leads to blaming the broker as everyone begins to to fully understand the reporting.
It is important for brokers to understand that you cannot perform this reporting on your end because you do not have the necessary data. We recommend that your role be one of facilitating all parties to ensure the reporting is completed. As you question your TPA(s) and PBM(s), to the extent that the reporting falls back onto the plan sponsor, we’ve got you covered.
It was for this reason we developed our solution to: