CAA Prescription Data Reporting

March 1, 2024

The Consolidated Appropriations Act, 2021 (CAA) requires plans and issuers offering group or individual health insurance coverage to submit information regarding the costs of prescription drugs and other health care services each year to the Center for Medicare & Medicaid Services (CMS). The 2023 data is due June 1, 2024.

For self-funded group health plans, most of the information should be available from a plan’s PBM, yet some information may only be available from the plan sponsor (such as premiums) and the TPA (such as paid healthcare services). Please note that the guidance on reporting clearly states that more than one entity can report on behalf of one health plan, as long as the entities do not overlap in terms of which requirements they report.

To assess your plan’s readiness, we are asking that you please answer the following questions, no later than March 22:

  • Has the Plan confirmed that the PBM will submit the prescription drug portion of the data to CMS, on the Plan’s behalf? This refers to the P2, D3-D8, and D9 files.
  • Does the Plan want WebTPA to submit the healthcare spending data directly to CMS, on the Plan’s behalf? This refers to the P2, D1, D2, and D9 files.
  • Does the Plan want WebTPA to provide the healthcare spending data to them, so that the Plan or the PBM will file the prescription and healthcare information, on the Plan’s behalf?

For more information, the CMS Reporting Instructions and other details can be found here.