The No Surprises Act (NSA), enacted as part of the Consolidated Appropriations Act, 2021 (CAA), includes transparency provisions requiring both grandfathered and non-grandfathered group health plans, and health insurance issuers in the individual and group markets, to submit information on prescription drugs and health care spending to the Departments of Labor Health and Human Services and the Department of Treasury and the Office of Personnel Management (The Departments).
This prescription drug data submission is called the RxDC report and is collected by the Centers for Medicare and Medicaid Services (CMS). RxDC Report for 2023 reporting year is due on 06/01/2024.
What Health Net of California Inc. and Health Net of Oregon (Health Net) are doing:
- Health Net successfully filed the previous 2022 RxDC report on behalf of its employer groups before 06/01/2023.
- Health Net will meet all regulatory obligations for 2023 reporting due on 06/01/2024.
- The Plan will not be requesting any data from the groups to complete plan list P2 and data file D1 on behalf of their clients.
- The plan will not be issuing any type if communications to the members/groups/brokers regarding RxDC filing (confirmation of filing completion, compliance with the reporting requirements, etc.) since it is not a regulatory requirement.
- The plan will not be establishing any contracts with the Groups regarding RxDC reporting since it is not a regulatory requirement.
- The group does not need to take any actions regarding the reporting or pay any fees to the plan for the reporting.