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As part of the Consolidated Appropriations Act of 2021 (CAA), group health plans and carriers will soon be required to report certain demographic and spending information about a plan’s prescription drug expenditures. The Departments will use this data to publish public reports on prescription drug reimbursements, pricing trends, and the impact of prescription drug costs on premium costs. The pharmacy reporting requirement generally applies to group health plans (both fully insured and self-insured) and carriers.
Employer Action Items
Group health plans and carriers are required to submit their first pharmacy report by December 27, 2022 (for calendar years 2020 and 2021) and will need the assistance of their carriers, TPAs, PBMs, or other similar vendors. Fully insured groups should confirm with their carriers that they will comply with this requirement and obtain this in a written document. Self-insured groups should identify and contract with their TPA or PBM to fulfill this requirement on the plan’s behalf.
Bim Group has confirmed that Anthem, Humana and UnitedHealthcare are submitting the required reporting on fully-insured employer groups’ behalf. FAQs or links to carrier statements are below containing this confirmation. We encourage you to review this information and keep it on file.
For self-funded employers, we have also confirmed that the TPAs and PBMs engaged with our clients are submitting the required reporting. Several self-funded employers may have received an outreach regarding providing premium amounts to the TPA, which Bim Group can assist with providing.
Following the December 2022 reporting deadline, the next CAA prescription drug cost reporting deadline is June 1, 2023 for the 2022 calendar year. We will continue to monitor with carriers and TPAs how the June 2023 filing will be handled and any pertinent changes that impact the employers’ responsibility.
If you have other questions, please contact your Account Management team.