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2024 CAA Prescription Drug Data Collection (RxDC) Reporting

2024 CAA Prescription Drug Data Collection (RxDC) Reporting

Blue Cross and Blue Shield of North Carolina (Blue Cross NC) is actively working on the June 1, 2024, RxDC Submission.

Overview

The Consolidated Appropriations Act (CAA) requires health insurers offering group or individual health coverage and Self-Funded or Administrative Services Only (ASO) group health plans to report data annually regarding prescription drugs and health care spending to the Departments of Health and Human Services, Labor, and Treasury (Tri-Agencies) (hereinafter the “RxDC Report”). This information must be submitted through the Health Insurance Oversight System (HIOS) access through the Centers for Medicare & Medicaid Services (CMS) Enterprise Portal.  

The next RxDC Report for reference year 2023 is due June 1, 2024.

Blue Cross NC approach and support

Blue Cross NC is actively working on the upcoming June 1, 2024, RxDC submission. As was the case for the last RxDC submission, some of the data elements required are not available in Blue Cross NC’s systems; therefore, on March 15, 2024, Blue Cross NC will send an electronic survey to the group contact of record for groups with coverage at any time in 2023 (fully-insured, balance funded and Self-Funded / ASO groups) and / or groups may access the survey via a link that will be provided herein to obtain the required information.

Submit RxDC survey

Blue Cross NC does not have the following data for fully insured groups and must receive this information through the electronic survey due no later than April 15, 2024.

If your group is subject to ERISA and was required to file a Form 5500 in 2023, you must provide your Plan’s Form 5500 number. Please note that this is only relevant to certain large group health plans for this purpose.  

The RxDC Survey Reference Guide (PDF) will assist you with collecting the necessary responses before completing your survey.

Complete your RxDC survey now.

The RxDC Report requests data about group health plans that in some cases will not be in the Blue Cross NC system because your group does not use Blue Cross NC for all its group health plan administration. For example, your group may use a different vendor / carrier for its pharmacy benefit management or a different carrier for your stop-loss insurance. To the extent that your health plan carves out its PBM, behavioral, wellness, or stop-loss services, additional information is requested through the survey to complete Blue Cross NC’s submission on your group’s behalf. Groups with these arrangements will also need to coordinate with their carve-out vendors / carriers.  

Blue Cross NC does not have some data for ASO groups and must receive this information through the electronic survey due no later than the deadline. Please use the link below prior to submitting your survey.

The RxDC Survey Reference Guide (PDF) will assist you with collecting the necessary responses before completing your survey.

Complete your RxDC survey now.

As a Blue TPA ASO group, you are responsible for filing with the regulatory agency. 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 the 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 Prescription Drug Data Collection (RxDC) page on CMS.gov.

If your group does not submit the data requested in the survey by April 15, 2024

Blue Cross NC will have no choice but to leave the required fields blank for your group. Blue Cross NC will submit the data in its system to CMS; however, your group’s data will not be complete without the required information gathered through the survey. Data elements not provided to Blue Cross NC by the survey response deadline will need to be submitted to CMS by the group or another reporting entity (i.e., another vendor or carrier). In other words, your group will need to submit D2 (and P2, as it is required for all submitters) directly to CMS through the HIOS platform by the regulatory deadline of June 1, 2024, to avoid any penalties.  

Failure to provide the requested information by the deadline will impact your Plan’s compliance with this mandate and will require direct submission by your Plan to CMS. Your group is responsible for the accuracy and completeness of the information provided to Blue Cross NC through this process. The group accepts any risk arising from its failure to provide any requested information to Blue Cross NC for reporting. 

What Blue Cross NC will submit on your employer group’s behalf

Blue Cross NC will generate and submit identifying information and medical claims in the aggregate for all groups that had active coverage during the reference year 2023 in the following reports:  

  • P2: Group health plan list
    • Additional information is needed from groups for this report to be complete.
  • D1: Premium and Life-Years in aggregate as permitted by the RxDC instructions
    • Additional information is needed from groups for this report to be complete.
  • D2: Spending by Category in aggregate as permitted by the RxDC instructions
    • Blue Cross NC has all the necessary information for this report to be complete. 

If your group uses Blue Cross NC as its pharmacy benefit manager (PBM), Blue Cross NC will provide CMS with the following prescription data in the aggregate for all groups:

  • D3: Top 50 Most Frequent Brand Drugs
  • D4: Top 50 Most Costly Drugs 
  • D5: Top 50 Drugs by Spending Increase
  • D6: Prescription Drug Totals
  • D7: Prescription Drug Rebates by Therapeutic Class
  • D8: Prescription Drug Rebates for the Top 25 Drugs 

If your group uses a different PBM, Your PBM carrier must submit P2 and D3-D8 data on your behalf.

  • If Blue Cross NC is your group’s stop-loss carrier:
    • Blue Cross NC’s reports to CMS will include the required stop-loss data.
  • If your group uses a different stop-loss carrier:
    • Blue Cross NC will collect this information via the survey.

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 nature of the permitted aggregate submission.

Please prepare yourself by using the RxDC Survey Reference Guide (PDF) with Calculations to determine what you will need to Complete your RxDC survey.

Reporting fees

Currently, Blue Cross NC has deferred assessing a fee for this report.

Additional resources

For questions regarding the RxDC Survey, please contact the Agent Contact Center (ACC) at 1-888-868-5598 and/or Group Service Advisors (GSA) at 1-877-237-6275.