There isn't a robust amount of new information in these instructions, but changes we've noted in addition to the aggregation restriction enforcement include:

Additional data elements to report. New for this year, one of the pharmacy benefit files (the D6) asks for pharmacy enrollment information. Also, a group health plan's plan list (P2) file must identify the types of carve-out benefits (i.e., pharmacy, medical, fertility, behavioral health). This information was optional last year.
Simplifications to the average monthly premium and premium equivalent calculations. The average monthly premium calculations are more straightforward because they are no longer reported on a per-member basis. Additionally, CMS has clarified that COBRA contributions and spousal and tobacco surcharges should be included in the average monthly premium paid by members. Finally, the instructions simplify the calculation of premium equivalents by removing restrictions on reporting on a cash basis.

You might be asking yourself, "Why should I start now?" Here's why: no good faith relief is available for this third reporting submission. In addition, no deadline extension is available, even though June 1, 2024, falls on a Saturday. As we said, time flies, so plan sponsors should begin working on their reporting strategy now. We encourage plan sponsors to:

Start to identify all your vendors with the required data;
Confirm the reporting entities for every data file and
Respond to all vendor surveys by the specified deadline.

Be sure to stay updated to help you navigate this new maze of RxDC reporting.

Instant Insights /

2024 compliance checklist: RxDC Is Back!

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