For those PBMs who have fully explored the new Drug Cost Reporting Requirements, you are likely aware that as a PBM you do not have access to all the data necessary to report. Specifically, you lack the data necessary to complete the plan level files (possibly) as well as data files 1 & 2. As we consult our PBM clients, this often comes as a surprise.
This creates a precarious situation for PBMs as the marketplace is under the impression that you ‘have it all covered‘ since, after all, this is supposed to be Drug Cost reporting. In reality, PBMs have a complex set of questions to consider in determining their optimal strategy. In the end, many will likely decide not to report on behalf of plan sponsors.
This creates a very challenging set of circumstances for the PBM to consider their options and not create a bottleneck on their portion of the reporting. It was for this reason we developed solutions to:
- Consult PBMs through understanding their options and develop their strategy
- Assist with data configuration through our relationship with SelfInsuredReporting.com
- Work directly with plan sponsors to service their questions and capture the information necessary to complete the TPA portion of reporting
- Launch our proprietary software and processes to assist all parties through the process
- Service plan sponsors and their brokers on an ongoing basis as questions or audits arise
One of our main goals for PBM clients is to ensure you aren’t blamed for not completing the reporting when in reality you control only a portion of the data for this entire requirement.