CMS releases revised RxDC reporting instructions for 2023

The Centers for Medicare & Medicaid Services (CMS) has issued revised instructions and templates for prescription drug data collection (RxDC) reporting for 2023, required under the Consolidated Appropriations Act, 2021 (CAA). The RxDC reporting deadline for the 2023 reference year is June 1, 2024.

As background, insurance companies and employer-sponsored group health plans must annually submit information about prescription drugs and healthcare spending to CMS.

Following are some key changes in the 2023 RxDC reporting instructions:

• Section 3.6 provides instructions on how to submit data when the plan list or data files exceed the maximum allowable size limit in the Health Insurance Oversight System.
• Section 4.2 provides updated instructions for populating the benefit carve-out field in the P2 plan list file. It also includes corresponding instructions clarifying how to represent plans in the P2 plan list file when the plan contributes to the prior year and restated fields but not to the current year fields.
• Section 5.6 provides that starting with the RxDC report for the 2023 reference year, the aggregation restriction will be enforced. The aggregation restriction requires that data submitted in the data files D1 and D3 to D8 must not be aggregated at a less granular level than the aggregation level used by the reporting entity that submitted the data in the D2 data file. This change will facilitate data analysis for developing the biannual public report required under the CAA.
• Section 6.1:
• Simplifies the calculation of the average monthly premium. Previously, the average premium was calculated on a per-member-per-month basis. Starting with the 2023 reference year, employers should divide the annual premium amounts by 12 instead of dividing by member months when calculating the average monthly premium.
• Clarifies that premium equivalents may be reported on a cash basis or on a retrospective basis.
• Provides additional details on amounts that should be included or excluded from premium equivalents.
• Section 8.1 clarifies that medical devices, nutritional supplements and over-the-counter drugs are excluded from prescription drug lists (D3 to D8) unless the National Drug Code for the product is on the CMS Drug and Therapeutic Class Crosswalk.
• Section 8.3 adds a column to the D6 data file to collect Rx enrollment information, which will report the total number of member months covered during the reference year under the pharmacy benefit for which pharmacy spending is reported.

Going forward

Employer plan sponsors will want to make sure that they and their third-party administrators, pharmacy benefit managers and carriers are using the revised reporting instructions when completing the RxDC reporting for the 2023 reference year.