The next RxDC report is due by June 1, 2024. To meet the requirement, Anthem will follow the same process as last year and file on behalf of fully insured and ASO clients. This includes ASO groups who opt-in to the D1 reporting. In order to submit all required information and ensure reporting accuracy, Anthem will request some information from clients.
Here is a summary of the communications Anthem will send to Large Group, Small Group, and National Account clients and the actions they must take to complete their required RxDC filing.
The week of February 12 – Fully Insured clients
- Anthem will email Fully Insured National Account, Large Group, and Small Group commercial clients, as well as clients with Minimum Premium, MEWA, and Anthem Balanced Funding plans. The email will include a link to an online form for these clients to provide the information we need to complete the filings on their behalf.
The week of February 12 – ASO client D1 opt-in
- Anthem will email ASO Large Group and National Account clients and provide a link for them to request that we file their 2023 D1 Premium and Life Years report. For those who opt-in, we will submit the aggregated data by market segment on their behalf for the benefits we administer and maintain.
The week of June 3, 2024 -- Confirmation of RxDC filing
- Anthem will email all Fully Insured and ASO commercial groups, including National Accounts, Large Group, and Small Group clients, to notify them that we have completed the required 2023 filing of prescription drug data on their behalf in compliance with federal regulations. This information will also be published to EmployerAccess Latest News.
For more information about the Consolidated Appropriations Act RxDC reporting requirements, please visit Anthem's CAA/Transparency Resource Center, CMS’ RxDC information page, or contact your Anthem representative.
Carefist intends to submit all RxDC files (P2, D1-D8) for both fully insured and self-insured clients. This requires them to collect certain information from each employer group that CareFirst serviced for any portion of 2023. Both the fully insured and self-insured markets require additional data elements, with certain nuanced complexities in the self-insured market.
CareFirst teams may be conducting outreach to assist in collecting this data and will provide more details in future communications.
Sentara Health Plans (Optima Health)
Sentara Health Plans is in the process of gathering the required data to meet the RxDC reporting timelines under the Consolidated Appropriations Act (CAA). They intend to file 2023 reference year data to CMS by the June 1, 2024, deadline on behalf of the following commercial group plans:
- Fully Insured Small, Mid-Market, and Large groups
- Self-Funded and BusinessEDGE® groups: if the group intends to file on their own behalf, please contact their Sentara Health Plans representative by February 23, 2024.
No action is required from the group or broker for the following commercial group plans; Fully Insured Small Group, Fully Insured Mid-Market, and BusinessEDGE.
To complete the filing for Fully Insured and Self-Funded Large groups, Sentara will require each group to supply additional information. These groups will receive an email with a link to complete an electronic form to collect the following data points:
- Large Group Fully Insured
- Average monthly percentage of premium paid by employee
- Average monthly percentage of premium paid by employer
- Large Group Self-Funded
- Total monthly premium equivalent by plan by tier
- Average monthly premium equivalent paid by employee
- Average monthly premium equivalent paid by employer
- Stop-loss premium if not administered by Sentara Health Plans
The form will be tailored to the group type and will only gather the required information needed to file the report on the group’s behalf. The deadline to submit the form is February 23, 2024.
More details on the regulations and requirements can be found on the CMS RxDC website. Sentara will also continue to update the frequently asked questions on their website as additional information becomes available.
UnitedHealthcare will relaunch the RFI Feb. 16 for clients with the extended completion deadline of April 10, 2024. The CMS instructions have resulted in changes to the calculation for member and employer premiums, as well as to the carve-out section on the worksheets.
Helpful links below: