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CAA 2021 Drug Reporting Requirement Update

The Consolidated Appropriations Act, 2021 (CAA), Title II, Division BB included a new reporting requirement for group health plans and health insurers to submit data regarding drug costs to the Department of Treasury, Department of Labor (DOL) and Health and Human Services (HHS). On November 23, 2021, interim final rules were released extending the deadline to submit the required information for years 2020 and 2021 to December 27, 2022.

On December 23, 2022, the Departments issued a frequently asked questions (FAQ) part 56 providing a submission grace period through January 31, 2023, plus additional clarifications and flexibility for the 2020 and 2021 data submissions. No enforcement action will be taken if the issuer or plan makes a good faith effort using a reasonable interpretation of the rule and guidance when submitting the required data.

The added clarifications and flexibilities for 2020 and 2021 data reporting include the following:

  • Reporting entities are allowed to make multiple submissions of data.

  • More than one entity may submit the same data file type for the same issuer or plan to avoid multiple entities attempting to consolidate data.

  • Submission of certain information may be sent by email instead of using the HIOS RxDC module.

  • Reporting on vaccines is now optional.

  • Amounts not applied to deductibles or out-of-pocket maximums as now optional.

The new guidance was published by the Departments due to concerns expressed regarding the complexity of the reporting requirement.

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