CMS Releases Updated RxDC Reporting Instructions for the 2022 Reference Year

CMS has released updated RxDC Reporting Instructions for the 2022 Reference Year. These updated instructions will apply to the 2022 calendar year reporting, due June 1, 2023.

According to the updated instructions document, the most significant changes to the RxDC reporting instructions from the prior year include the following:

• Specified that requirements do not apply to retiree-only plans. (Section 1.4)
• Clarified reporting related to U.S. territories. (Section 1.5)
• Add- option for multiple vendors to submit same data file for plan/issuer(Section 3.3)
• Add- option to create multiple submissions in HIOS. Same reference year. (Section 3.5)
• Rearranged plan list instructions addressing P1, P2, and P3. (Section 4)
• Replaced column for HIOS Plan ID in P2. column to collect benefit carve-out data. (Section 4.2)
• Renamed columns in D1 – D8 to “Company Name” and “Company EIN” may choose to aggregate data at the plan sponsor, carrier, reporting entity, or other company level, rather than only the issuer or TPA level. The purpose of these columns has not changed, only the names. (Section 5.2)
• Renamed state reference in D1 – D8 from “State” to “Aggregation State” to more clearly differentiate from the column labeled “States in which the plan is offered” in plan lists P2 and P3. The purpose of this column has not changed. (Section 5.2)
• Extended suspension of the aggregation restriction. (Section 5.6)
• Renamed column J in D1 from “ASO/TPA Fees Paid” to “Admin Fees Paid” to reflect that self-funded plans pay administrative fees to other types of companies, such as PBMs. The purpose of the column has not changed. (Section 6.1)
• Specified that prescription drug rebates should be subtracted from premium equivalents in D1 regardless of whether the rebate received in the reference year is retrospective or prospective. (Section 6.1.)
• Specified that stop-loss reimbursements should be subtracted from premium equivalents in D1. (Section 6.1)
• Specified that stop-loss reimbursements should not be subtracted from total spending in D2. (Section 7.1)
• Specified that rebates expected but not yet received should be subtracted from total spending. (Section 7.1 for drugs covered under a medical benefit and Section 8.4 for drugs covered under a pharmacy benefit.)
• General edits for clarity.

The CMS/HHS document is published here:  https://regtap.cms.gov/reg_librarye.php?i=3860

PAI has completed our first request for information/data related to RxDC reporting via Smart Sheet to our customers.  If you have something to report, please be sure to respond to our request as appropriate at your earliest convenience.  You can find a PAI published FAQ here: RxDC FAQ.pdf