On April 10, 2024, the Centers for Medicare and Medicaid Services (CMS) announced that the Prescription Drug Data Collection (RxDC) submissions portal is now open for 2023 submissions. The system is known as Health Insurance Oversight System (HIOS). Employers who are responsible for submitting any of the required files directly must be registered with HIOS.
Who Needs to Register and Submit Files?
As a reminder, the required process includes the submission of eight data files. The reality of who is responsible for filing the various data file elements is a function of whether plans are fully insured or self-funded AND how the self-funded carriers are contracted to handle the filing.
Fully Insured Employers: Fully insured employers will rely on their carriers for the full submission process, assuming the client has participated in the data gathering process if required. It is important to remember that employers must obtain and retain written confirmation that their carriers will be handling the RxDC submission on their behalf. Many fully insured carriers are requiring employers to submit or confirm certain data points by a specified deadline in order for the fully insured carrier to complete the reporting on the employer’s behalf.
Self-Funded Employers: Self-funded employers will need to coordinate with their Administrative Services Only (ASO) and Pharmacy Benefits Manager (PBM) partners to confirm filing requirements. As a reminder, while most of the data is in the hands of the PBMs, some of the required data elements are only known by the employer. Therefore, some measure of coordination will be required. Some vendors are collecting required employer data from clients and doing the complete filing on their behalf. Other vendors are splitting the file submission process between the PBM and the employer.
Some action is required for all self-funded employers. Depending on the structure of the arrangement, either:
- Provide the required data to PBM vendor for them to complete the full filing (when vendor has responsibility for submitting all files).
OR
- Register for HIOS portal and submit required files directly (when employer has direct responsibility for submitting any data files).
Resources for Navigating Registration
For those self-funded employers who must submit any data files directly, CMS has provided several resources for navigating the registration process:
The registration process can take several weeks, so employers are encouraged to register early.
Deadline
The RxDC filing for the 2023 reference year submission is due June 1, 2024, regardless of renewal term.
