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May 2024 Benefits Buzz: RxDC Reporting Deadline and ACA Update

May Benefits Buzz RxDC prescription drug

RxDC prescription drug report is due by June 1 

Group health plans must annually submit detailed information on prescription drug and healthcare spending to the federal government. This reporting is referred to as “prescription drug data collection” or the “RxDC report.” The next RxDC reporting deadline is Saturday, June 1, covering data for 2023.  

Employers should confirm they are complying with the 2024 RxDC reporting deadline, such as providing information to third-party vendors on a timely basis.  

The RxDC report is comprised of several files, including those that require specific plan-level information, such as plan year beginning and end dates, and enrollment and premium data. It also includes files that require detailed information about medical and pharmacy benefits.  

RxDC reports must be submitted through CMS’ online RxDC portal, which includes updated reporting instructions and other resources.  

Employers commonly use third parties, such as insurance issuers, administrators and pharmacy benefit managers, to submit RxDC reports on their health plans behalf. Employers using third parties to submit RxDC reports must ensure that this reporting responsibility is reflected in a written agreement with the third party.  

Employers may work with multiple third parties to complete the RxDC report for their health plans. For example, a self-insured employer may use both its TPA and PBM to submit different portions of the RxDC report. An RxDC submission is considered complete if CMS receives all required files, regardless of who submits them. 

Court ruling expected soon on free preventive care 

The 5th U.S. Circuit Court of Appeals is expected to issue a decision within the next few months regarding the constitutionality of the Affordable Care Act’s preventive care mandate. The ACA requires non-grandfathered health plans and health insurance issuers to cover a set of recommended preventive services without imposing cost-sharing requirements, such as deductibles. 

In March 2023, the U.S. District Court for the Northern District of Texas struck down a key component of the ACA’s preventive care mandate. The court ruled that the preventive care coverage requirements based on an A or B rating by the U.S. Preventive Services Task Force on or after March 23, 2010, violate the U.S. Constitution. 

The Biden administration appealed the District Court’s decision to the 5th Circuit. A ruling by the 5th Circuit is expected soon, possibly followed by an appeal to the U.S. Supreme Court. 

The 5th Circuit could reverse or uphold the District Court’s ruling. However, for now, non-grandfathered health plans and issuers must continue to cover the full range of preventive care services required by the ACA without cost sharing. If the 5th Circuit rules that a key component of the ACA’s preventive care mandate is unconstitutional, employers will need to consult with their issuers or TPAs to assess the impact on their health coverage. 

Did you enjoy this May Benefits Buzz? If you haven’t already, read our April issue to learn about the ERISA enforcement results and IRS updates. Contact TruePlan today for more information or to explore our employee benefits services.  

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