Drug Reporting Rules Present Challenges for Many

Summary

A new prescription drug reporting mandate, adopted as part of the 2021 Consolidated Appropriations Act (CAA) (Pub. L. No. 116-260), requires group health plans and health insurers to report detailed data about prescription drug pricing (including rebates) and healthcare spending. The first reports are due by Dec. 27, 2022, and annually thereafter. The departments of Labor, Treasury, and Health and Human Services will use the information to prepare a biannual, publicly available report. The departments have issued an interim final rule (IFR) detailing the data to report, and the Centers for Medicare & Medicaid Services (CMS) has issued submission instructions describing the mechanics of the reporting process. This article summarizes the prescription drug reporting rules and identifies compliance challenges facing group health plans.