Pharmacy benefits and costs reporting Prescription Drug and Data Reporting portal live for customers

The government Prescription Drug Data Collection (RxDC) portal for customers to submit their data for pharmacy benefits and costs reporting under CAA is now live. Support materials and guides are also available via the portal.

The Centers for Medicare and Medicaid Services (CMS) portal is open for customers to submit their data that is not already submitted by UnitedHealthcare or one of their other vendors.

UnitedHealthcare will submit the data by December 27, 2022, as outlined in the CAA pharmacy benefits and costs reporting guide.

CMS portal resources and information

• CMS reporting instructions and deadlines
• Sign in to CMS.gov
• Health Insurance Oversight System (HIOS) RxDC User Manual (cms.gov)
• HIOS Portal User Manual (cms.gov)

Government announces D1 Premium Safe Harbor

The Safe Harbor is in reference to 2020 and 2021 reference years only and states: “If you have obtained the required information, you must report it. However, the Departments recognize there may be significant challenges to obtain information about employer premium contributions, especially when a contractual relationship began before the passage of the CAA. Accordingly, the Departments will not take enforcement action related to the requirement to report average monthly premium paid by employers versus members for the 2020 and 2021 reference years if those data elements are reported in RxDC report for the 2022 reference year and all future reference years.”

Member counts and retirees

Group health plans (P2) require the member count as of December 31 of the reference year. UnitedHealthcare will include all members in the policy, including retirees, in its pharmacy benefits and costs data submission. UnitedHealthcare does not have the ability to exclude retirees from reporting. While retirees are not required to be reported, the available guidance does not indicate they cannot be part of the data submitted.

Additional resources

UnitedHealthcare approach to CAA pharmacy benefits and costs reporting

CAA FAQ including section on pharmacy benefits and costs reporting

For questions, please contact your broker or UnitedHealthcare representative.