New RxDC Reporting Instructions: Good/Bad News Ahead of June 1 Deadline


Summary

As June 1 looms for group health plans and insurers to report medical and pharmacy data for the 2022 reference year to CMS, employers may find the recently-released prescription drug data collection (RxDC) instructions a mixed bag. CMS has clarified processes and templates, better defined key terms, and continued some of the flexibility available for the first RxDC reporting cycle. However, important relief provided in the first reporting cycle has not been renewed, including the much-needed general good faith effort relief issued in FAQs Part 56. As a result, more plan sponsors may need to submit some amount of 2022 data directly to CMS (rather than relying entirely on their vendors).