Dec 15, 2022
Blue Shield of California is preparing to submit data files as required by the Consolidated Appropriations Act, Section 204 – Pharmacy Drug Cost Reporting for reports due December 27, 2022. This federal mandate requires health plans and group plan sponsors to report certain information on prescription drug coverage and health care costs to the Center for Medicare & Medicaid Services (CMS). The Tri-Agencies, consisting of the Health and Human Services, the Department of Labor, and the Department of the Treasury, will then publish a report on prescription drug trends and the impact on premiums on their respective websites.
Group plan sponsors will receive an email communication later this week, outlining reporting responsibilities for reports due in December. A detailed matrix of reporting responsibilities for each of the data elements by market segment, funding type, and benefit carve in/out status can be found here.
The regulatory agencies are allowing a good faith estimate for D1 Premium and Life Year data for reports due this year, hence Blue Shield will be submitting premium contribution estimates for all groups except those groups with benefits carved out, such as pharmacy or stop loss, in which case the group is responsible for submitting D1 Premium and Life Year data. Blue Shield anticipates further guidance from the CMS on capturing and reporting D1 Premium and Life Year data for the years following and will share more information as this becomes available.
There will not be any updates to group service agreements for this year, however Blue Shield is assessing if updates may be needed for the following year.
To learn more about the CAA Section 204 provision, including reporting instructions, refer to this Centers for Medicare & Medicaid Services page.
Please view the CAA FAQ document or reach out to your Amwins Connect Sales Representative with any questions you may have.
