2024 CAA Prescription Drug Data Collection (RxDC) Reporting

Self-funded groups only may choose to submit their D1 reporting data via the HIOS platform but must have indicated this choice within the survey no later than April 15, 2024. If your self-funded group chose to submit D1 (and P2 as it is required from all submitters) and indicated as such within the survey by the deadline, Blue Cross NC did not submit D1 of your group’s behalf but submitted all other relevant data on your group’s behalf.

No. Blue Cross NC does not process data required for section P2 and D1 more specifically explained below. Blue Cross NC reached out to groups individually with a survey to request the necessary information. Groups needed to submit the data back to Blue Cross NC by April 15, 2024, for Blue Cross NC to fully complete the report. If Groups failed to respond to the requests for data, it will impact the Group’s compliance with the mandate and groups will be required to submit the information to CMS directly.

For P2, Blue Cross NC does not possess the Form 5500 Plan Number. The CMS instructions state, "If applicable, enter the 3-digit plan number reported on the IRS Form 5500 filed with the Department of Labor. If there is more than one value, separate them with a semicolon." Blue Cross NC requested Form 5500 numbers from those Groups subject to ERISA and must file a 5500 number with the IRS and as such, would have data applicable to this P2 field. For reference, a Group may find their Form 5500 plan number by visiting the US Department of Labor Form 5500 Search Tool. 

For D1, Blue Cross NC must report Premium and Life-Years. For Self-funded plans and other arrangements that do not rely exclusively on premiums, Blue Cross NC must report the Premium Equivalent Amounts. The Stop Loss Premium Paid is an element of the required Premium Equivalent Amounts calculation. Blue Cross NC has this information for those Groups that have Stop Loss coverage through Blue Cross NC, but for those that use other Stop Loss carriers, we do not possess this information and have requested it as applicable. Blue Cross NC also does not process the monthly premium paid by employers versus employees. Blue Cross NC must collect this data for the relevant reference year.

No. Blue Cross NC is set up in the HIOS system and will be reporting the RxDC report pursuant to the CMS instructions. Groups do not have to set up an account for the submission to be accepted on their behalf UNLESS the group fails to complete the survey with additional information required by April 15, 2024.

Yes. If your Group had coverage with Blue Cross NC during the relevant reference years, the data will be reported on its behalf.

If an employer offers both fully insured and Self-Funded health plans, the employer must submit a survey for each funding arrangement. In other words, the employer would submit one survey for the fully insured plans and one survey for the Self-Funded plans. Please note that balance funded / level funded health plans are self-funded health plans.

So long as your group’s health plan all fall within the same funding arrangement (fully insured or self-funded / ASO), your plan numbers should be separated by semicolon within the survey and all dollar amounts should be reported in total for all plans for the group. Multiple survey submissions are NOT required. See question below for additional information in this regard. 

The information submitted in P2, specifically the Group Health Plan Name and Group Health Plan Number will tie multiple submission to a single employer / group health plan and must be submitted by each entity submitting a report on behalf of an employer / group health plan. Clients will need to coordinate with other carriers / vendors based on carve-out arrangements to submit other relevant data. Clients need to confirm their other carriers / vendors are submitting the appropriate data in the context of the services they provide to your Plan. Blue Cross NC expects that carve out vendors will submit the following data within the context of the services they provide as Blue Cross NC will not provide that data on the Plan's behalf:

• Carve Out Pharmacy carriers should submit P2 and D3-D8 data
• Carve out Behavioral carrier that pays claims should submit P2 and D2
• Carve out Wellness carrier that pays claims should submit P2 and D2

Please note, D2 data is aggregated at the vendor / carrier reporting entity level. 

This information is intended to be informational only and is a guide based on the direction provided by CMS in the RxDC reporting instructions. Plans and their carriers should consult their own legal and compliance teams on compliance with this mandate.

These are fees that are to be included in the premium equivalent calculation. Groups that have carve out arrangements and are assessed these fees by their carve out vendor(s) need to report this amount via the survey. If a group does not have any carve out arrangements, Blue Cross NC has this information for your group, and you may respond 0 within the survey.

We will submit the last submission if a group enters multiple submissions for a funding arrangement.

The report includes general information identifying the insurer or plan as follows:

• Enrollment and premium information, including average monthly premiums paid by employees and the employer
• Total health care spending, broken down by type of cost (e.g., hospital care, primary care, specialty care, prescription drugs, and other medical costs including wellness services) by enrollees and by employer or insurer
• Prescription drug spending by enrollees and employers or insurer
• 50 most frequently dispensed brand prescription drugs
• 50 costliest prescription drugs by total annual spending
• 50 prescription drugs with the greatest increase in plan or coverage expenditures from the prior year
• Prescription drug rebates, fees, and other remuneration paid by drug manufacturers to the plan or issuer in each therapeutic class of drugs, as well as for each of the 25 drugs that yielded the highest amount of rebates
• Impact of prescription drug rebates, fees, and other remuneration paid by prescription drug manufacturers on premiums and out-of-pocket costs

As required, reporting will be aggregated at the state / market level, rather than separately for each plan. As such, each group’s data except its identifying information is not identifiable within the report and cannot be pulled out from the submission. The federal guidance provides uniform standards and definitions, including standards for identifying prescription drugs regardless of the dosage strength, package size, or mode of delivery. There are uniform standards for submitting data that are intended to allow the Tri-Agencies and US Office of Personnel Management (OPM) to conduct meaningful data analysis and identify prescription drug trends. More information on the Reporting Instructions can be found on the CMS 2023 RxDC Instructions (PDF).

CMS RxDC Instructions can be found on the 2023 RxDC Instructions (PDF).   

Groups may sign up for email announcements and register for training webinars relevant to this topic at the Registration for Technical Assistance Portal (REGTAP). 

As a Blue TPA ASO group, you are responsible for filing with the regulatory agency.

Neither Blue Cross NC nor Brighton Health Plan Solutions will file on your behalf.

• Blue Cross NC will supply a report with the medical data required for the filing by May 15.
• Blue TPA ASO groups must obtain the required Pharmacy data from your pharmacy benefits manager (PBM) or request that your PBM file on your behalf.
• The appropriate EIN to submit is Blue Cross EIN number: 56-0894904.
• The deadline for the 2023 reference year report is June 1, 2024.

If you need additional information and instructions for filing, please visit the CMS Prescription Drug Data Collection (RxDC) page.

Blue Cross NC is unable to incorporate external data or make changes to data after the Blue Cross NC April 15, 2024, deadline. If there are data mismatches, Blue Cross NC will reconcile with CMS directly as it is brought to Blue Cross NC’s attention.

Yes, Blue Cross NC will submit the appropriate narrative statement(s) for each data file submitted explaining the required information as it relates to aggregate data provided to CMS on behalf of all groups. Please note, Blue Cross NC is unable to customize the narrative by group given the permitted aggregate nature of the report.

No. Blue Cross NC will report our data in aggregate as supported by CMS aggregation instructions. As such, individual group submission will not be available or provided to each group. Blue Cross NC will communicate when it has submitted the report and the date upon which it was done.