In mid-February, CMS released revised instructions for the highly anticipated third RxDC reports, which encompass the 2023 calendar year and are due by June 1, 2024. The new instructions may cause employers and plan sponsors to lean towards making plan-level submissions instead of relying on their vendors to make aggregate submissions on their behalf. The instructions mimic the prior versions, so plan sponsors should not worry about significant deviation. 

There is a "first," however. For the first time, CMS will enforce the aggregation restriction, a provision that CMS had suspended for the first two reporting cycles. The cause for concern here is that plan sponsors cannot rely on their PBM's aggregate submission of pharmacy data. Instead, they will have to submit plan-level Rx data. So, if this already sounds like a migraine waiting to happen, let's pause and refresh for a moment.

Related: Mental Health Parity and Addiction Equity Act, part 1: How it began