Legal Alert

Reminder: Reporting Requirement for Health Care Costs One Month Away

by Edward I. Leeds and D. Finn Pressly
May 1, 2023

Health plan sponsors and health insurers will need to report prescription drug and other health plan costs (RxDC reporting) for 2022 by June 1, 2023. Unlike the RxDC reporting requirements for 2020 and 2021, this deadline is not expected to be delayed.

Plan sponsors and insurers will benefit from the relaxation of some of the reporting requirements. These changes, which were largely introduced in FAQs issued late last year, have since been incorporated into the reporting instructions. Perhaps most significantly, this guidance allows more than one reporting entity to submit information for a particular data type. Plans should make sure that they have appropriate arrangements in place with their insurers, pharmacy benefit managers, and third-party administrators to meet their obligations and to understand if they themselves will need to report any data.

The June 1 deadline will be in place for this reporting requirement in future years, so health plan sponsors should build compliance with this requirement into annual health plan administrative processes.

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