HHS has launched revised directions for group well being plans and insurers to report prescription drug and well being care spending knowledge, as required by the Consolidated Appropriations Act, 2021 (see our Checkpoint article). As background, rules describing the content material and timing necessities for knowledge submissions have established that plans and insurers should submit annual spending, premium, and enrollment data based mostly on the “reference 12 months” (i.e., the calendar 12 months instantly previous the calendar 12 months during which the info submission is due) (see our Checkpoint article). Reporting directions had been launched for the 2020 and 2021 reference years (see our Checkpoint article).

Reporting directions for the 2022 reference 12 months are actually obtainable. The directions present step-by-step steering for submitting knowledge by means of the RxDC module within the Well being Insurance coverage Oversight System (HIOS). The directions additionally handle who should report and when, and embrace detailed explanations of spending classes and knowledge aggregation guidelines. Amongst different issues, the 2022 reporting directions have been revised to permit a number of distributors to submit knowledge recordsdata on behalf of the identical plan or insurer. In addition they handle suspended knowledge aggregation restrictions and supply further steering on reporting prescription drug rebates.

EBIA Remark: The deadline for the 2022 reference 12 months report is June 1, 2023 (see our Checkpoint article). The directions affirm that account-based plans (resembling HRAs) and plans that present solely excepted advantages (e.g., limited-scope dental and imaginative and prescient plans, hospital or different mounted indemnity insurance coverage, and disease-specific insurance coverage) usually are not required to submit a report. For extra data, see EBIA’s Well being Care Reform guide at Part XXXVI.L (“Prescription Drug and Well being Care Spending Reporting”). See additionally EBIA’s Self-Insured Well being Plans guide at Part XXIX.D.4 (“Prescription Drug and Well being Care Spending”) and EBIA’s ERISA guide at Part XXI.C (“Warning Relating to Extra Obligations”).

Contributing Editors: EBIA Workers.