Prescription Drug Reporting Due June 1

Under the Consolidated Appropriations Act, 2021, self-funded group health plans are required to submit certain information related to prescription drug and other health care spending to the Department of Labor, the Department of Health and Human Services, and the Department of Treasury (Departments).

Plans Required to Report: All group health plans must report the required information (except for church plans).  Reporting requirements do not apply to excepted benefits, however, nor to retiree-only plans with fewer than two participants who are current, active employees.

Due Date: Reporting runs on a calendar-year basis, with a reporting year referred to as a “reference year” (meaning the prior calendar year).  The next report is due June 1 and must include data for the 2023 reference year (calendar year).

Reporting Elements: Reports must include a variety of plan-related information that will be aggregated at the state or market level.  Specifically, the reports must include information about the impact of complex drug pricing mechanisms — rebates, fees, and other remuneration paid by drug manufacturers — on premiums, as well as a wide variety of information on overall plan spending beyond prescription drugs, for comparison with prescription-drug spending.  The Departments issue biannual public reports on prescription drug reimbursements under group health plans, prescription drug pricing trends, and the impact of prescription costs on premium rates.

Assistance from ASR: ASR is coordinating efforts with our PBM partners to meet the prescription-drug reporting requirement for our clients.  We will reach out to clients to obtain information necessary to file the report.

If you have questions on this reporting requirement, call ASR Health Benefits at (616) 957-1751 or (800) 968-2449.