CAA Prescription Drug Benefit Reporting Due June 1, 2024

The Consolidated Appropriations Act of 2021 (CAA) requires all group health plans and health insurers to submit information regarding the costs of prescription drug costs and health care services to the federal government. For 2023 data, information must be submitted to Centers for Medicare & Medicaid Services (CMS), by June 1, 2024.

• The 50 brand name prescription drugs for which the plan most frequently paid claims and the total number of claims paid for each of those drugs.
• The 50 prescription drugs for which the plan had the greatest expenditures and the amount paid for each of those drugs.
• The 50 prescription drugs for which the amount of expenditures increased the most over the previous year and amount of the increase of each drug.
• The total amount spent on health care, broken down in a variety of ways, such as:
• Type of cost (hospital, primary care, specialty care, prescription drugs, and other costs
• Prescription drug expenditures by the plan and enrollees
• The average monthly premiums paid by the plan and by enrollees
• The impact of rebates and similar amounts paid by drug manufacturers, including the amounts paid for each therapeutic class of drugs and for the 25 drugs for which amounts paid were the largest.
• Reductions in premiums and out-of-pocket costs associated with drug manufacturer rebates and similar payments.

Most of the required information will be held by a plan’s carriers, pharmacy benefit managers and other plan vendors. Those entities may contractually assume responsibility for completing and submitting the reports on behalf of the plan. Insured plans may transfer all liability if the insurer fails to meet the reporting obligations. However, a self-funded plan will remain liable for a vendor’s failure, but it can protect itself through contracts with its vendors. Vendors may file the reporting on behalf of a self-funded plan.

If the sponsor of a self-funded plan chooses to report on its own, then it will need to collect all of the information from its various vendors. Much of the reporting will require coordination between the various plan vendors.

Benecon is working with our various vendors to obtain specific information as to their intentions regarding these requirements. The level of vendor assistance will vary widely with each vendor. Many vendors still have not made a determination as to their course of action for the upcoming filing. As Benecon obtains information, we will pass it along to our partners.

In the meantime, Benecon highly encourages all benefit producers and groups to reach out directly to their carrier partners to obtain specific agreements and confirmations as to their reporting plans for the upcoming June deadline. The carriers will also be able to provide direction to the plan of any outstanding information required by the plan itself.

This will be a challenging requirement for both plans and their vendors. The mandate requires a great level of coordination and information. Benecon will continue to monitor this situation and provide updates as they become available.