The FAQ also provides further "clarifications" to the RxDC rules, including:

Multiple submissions by the same reporting entity is allowed. To prevent unnecessary duplication, the RxDC rules generally bar multiple submissions of the same data file. However, the FAQ waives this requirement. Reporting entities may now create more than one submission for the year, instead of including the data of all clients within a single set of plan lists and data files for the year.
Submissions by multiple reporting entities is allowed. More than one reporting entity may submit the same data file type on behalf of the same plan or issuer, instead of working together to consolidate all of the plan or issuer's data into a single data file for each type of data.
Aggregation restriction is suspended. The RxDC rules require that reporting entities submitting the required data on behalf of one or more plans or issuers must be aggregated to at least the aggregation level used by the reporting entity that submits data on the total annual spending on health care services on behalf of those plans or issuers. This requirement is waived for 2020 and 2021 data only.
Submission of premium and life-years data by email is available for certain group health plans. Email submissions are permitted where the reporting entity is only submitting plan lists, premium and life-years data and the narrative response (if no other data is submitted).
Reporting on vaccines is optional. Reporting entities may — but are not required to — incorporate certain vaccines in their data files.
Reporting amounts not applied to the deductible or out-of-pocket maximum are optional. Reporting entities do not have to report a value for "Amounts not applied to the deductible or out-of-pocket maximum" and the "Rx Amounts not applied to the deductible or out-of-pocket maximum."

Instant Insights /

Last minute relief for prescription drug reporting

More From HR Executive

Related Stories

Recommended For You