A reporting entity is someone who submits some or all of the required information to the departments. Sounds straightforward, right? Not quite … Like a lot of things the more you dig into the details the more complicated it becomes.
- For fully insured groups this will be your carrier, so that is easy.
- For self-insured, level funded and minimum premium funded accounts, the plan sponsor is responsible.
So you might be thinking, “well this is no big deal, my TPA and PBM will do the reporting?”
Yes and no. The problem is that the data files require a lot of coordination between the Plan Sponsor, TPA and PBM in order to get the right data in the right spots. Reporting entities can be anyone who submits data and it is not necessary that one party submit all of the data.
The challenge arrives because no one entity has all of the information necessary to report to the departments. This is particularly challenging because (a) this is new reporting and (b) PBMs are telling their clients “we have you taken care of”.
HOWEVER, the PBM does not have all of the data necessary to do the reporting. What they mean by this statement is that they have data files #3 – #8 taken care of, but this is only part of the reporting required.
Learn more about how we help plan sponsors stay compliant at DrugCostReporting.com