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.
Missed survey deadline
Our online survey closed on April 15, 2024.
If your group did not submit the data requested in the survey before it closed, the missing data elements need to be submitted to CMS by the group or another reporting entity (i.e., another vendor or carrier).
To avoid any penalties, your group must submit D1 and P2 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. The group accepts any risk arising from its failure to provide any requested information to Blue Cross NC for reporting.
For more info on submitting your missing data directly to CMS through the HIOS platform, please review the CMS guides:
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 previous 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 sent 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). Groups were also able to access the survey online.
Submit RxDC group data
Review our group coverage guides below to find out how to submit your required group data.
Blue Cross NC does not have the following data for fully insured groups and must receive this information through the electronic survey.
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 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 of 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 behavioral, wellness, stop-loss, or pharmacy benefits manager (PBM) services, additional information is requested. Groups with these arrangements will also need to coordinate with their carve-out vendors / carriers.
As a Blue TPA ASO group, you are responsible for filing with the regulatory agency. Neither 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 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.
What Blue Cross NC will submit
Blue Cross NC will submit several important documents on behalf of your employer group. This includes generating and submitting 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 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 collected this information via the survey.
Blue Cross NC will submit the appropriate narrative statement(s) for each data file submitted and will also explain 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.
Didn’t complete the Blue Cross NC RxDC survey and submit all required information? You must submit your data directly to CMS through their Enterprise Portal.
Reporting fees
Currently, Blue Cross NC has deferred assessing a fee for this report.
Additional resources
For questions regarding the RxDC submission, please contact the Agent Contact Center (ACC) at 888-868-5598 and / or Group Service Advisors (GSA) at 877-237-6275.
Blue Cross and Blue Shield of North Carolina does not discriminate on the basis of race, color, national origin, sex, age or disability in its health programs and activities. Learn more about our non-discrimination policy and no-cost services available to you.
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