Prescription Data Collection (RxDC) Reporting Requirements, Consolidated Appropriations Act, 2021 (CAA) Section 204
This notice provides information regarding WebTPA’s plans to assist our clients with their CAA Section 204 reporting obligations. We previously shared an overview of the reporting requirements, and we asked a few questions pertaining to your Plan’s submission of the various files. We have also been communicating with many of the PBM partners that our clients utilize to ensure that we are in sync with how they intend to submit data on behalf of our joint clients. Please note that this particular reporting exercise is largely prescription drug data, so the data that WebTPA will be able to provide in support of our clients, will be rather limited in scope.
Below is a list of the files and the entity that holds the data for each file.
Files P1 – P3, Organization Type File
Plans identify as only one of the following Organization Types and files only one of the following files:
- P1: Individual and Student Markets
- P2: Group Health Plans (e.g., most commercial business)
Your Plan(s) would fall within the definition of P2
- P3: Federal Employees Health Benefits Plans
Files D1 – D8
WebTPA will report files P2, D1, D2 and we may require additional information from the plan on D1 depending on what information we receive from you today for your P&L statement. Files D3 – D8 are specific to prescription data only and should be reported by your PBM.
File D9 Narrative Response
The D9 file is a Narrative Response and should be submitted in Word or PDF format. The narrative contains questions related to the collection of both healthcare and prescription data contained in the other files. WebTPA will provide the D9 healthcare answers and the PBM is allowed to submit a separate D9 with the prescription answers.
WebTPA’s Assistance with the Plan’s RxDC Reporting
Although you may have already responded to our previous questions about the Plan’s filing, please review the three options outlined below so we are in alignment about how the reporting will be completed for your plan.
WebTPA reports and submits files P2, D1, D2, and D9 in the CMS-required format on the HIOS Portal, on behalf of your Plan(s). This option does not include submitting the data files D3-D8, which contain prescription data from the PBM. We will coordinate with your PBM to ensure that the accompanying files will be submitted and matched to the files we are submitting on your behalf.
WebTPA reports files P2, D1, D2, and D9 to you, in the CMS-required format and you will be responsible for submitting these files into the HIOS Portal. If you are also submitting the D3 – D8 prescription files (rather than the PBM), please advise of the timeframe you will receive the PBM files so we can coordinate our timing as well.
WebTPA provides files P2, D1, D2 and D9 to your PBM, in the CMS-required format directly to your PBM. The PBM will be responsible for submitting all files (prescription and healthcare) into the HIOS Portal.
If the above options will not meet your plan needs, please notify your Account Executive directly to discuss your specific situation and issues involved to determine next steps. Please note that we are supporting the options listed above at no additional charge to our clients and have architected our reporting solution accordingly, so any requests to provide reporting above and beyond these requirements will be at a cost to the plan.
For questions, please contact your WebTPA Account Executive.