Who must submit Prescription Drug & Healthcare Cost Reporting?

Drug Cost Reporting (Section 204 of the CAA) requires health plans (plans) and carriers (issuers) offering group or individual coverage to annually submit detailed financial information about prescription drugs and health care spending to the Department of Health and Human Services (HHS), the Department of Labor, and the Department of the Treasury (the Departments).

This reporting includes self-insured plans and also grandfathered plans and all data must be submitted via the CMS portal.

Here is a list of who IS required to submit reporting:

  • Health insurance issuers offering group coverage
  • Health insurance issuers offering individual market coverage, including:
    • Student health plans
    • Plans sold through the Exchange
    • Plans sold exclusively outside of the Exchanges
    • Individual coverage issued through an association
  • Fully-insured and self-funded group health plans, including:
    • Non-federal governmental plans, such as plans sponsored by state and local government
    • Church plans that are subject to the Internal Revenue Code
    • FEHB plans


Here is a list of who is NOT required to submit reporting:

  • Account-based plans, such as health reimbursement arrangements
  • Excepted benefits including but not limited to:
    • Short-term limited-duration insurance
    • Hospital or other fixed indemnity insurance
    • Disease-specific insurance
    • Medicare Advantage and Part D plans
    • Medicaid plans
    • State children’s health insurance program plans
    • Basic Health Program plans