Federal Prescription Cost Reporting System Takes Shape

Four federal agencies are starting to set up what could be a large, complicated prescription plan cost reporting program.

On Monday, the agencies put out a request for ideas on how to implement the Consolidated Appropriations Act of 2021 (CAA 2021) drug cost transparency provision, which requires each health insurance issuer or self-funded employer health plan to send the government an annual report providing:

• General size and location information for each plan or coverage the payer offers.
• A list of the payer’s 50 most frequently dispensed brand-name prescription drugs.
• The total number of paid claims for each of those 50 drugs.
• The 50 most costly prescription drugs by total annual spending.
• The amount the payer expects to spend each year on the 50 most costly drugs.
• The 50 drugs with the great increase in plan spending, when compared with spending for the previous year.

The agencies involved are the U.S. Department of Labor’s Employee Benefits Security Administration (EBSA); the U.S. Personnel Management Office (OPM); the U.S. Department of Health and Human Services (HHS); and the Internal Revenue Service.

The New Reports

Every two years the agencies are supposed to use the annual reports to prepare  analyses of the U.S. prescription drug market, and which drugs are causing the most cost problems.

The Centers for Medicare and Medicaid Service, an arm of HHS, already posts detailed information about Medicare prescription spending.

The rules outlined in the request for information call for commercial payers to send the government  the first batch of drug cost reports by Dec. 27, 2021, and then to file subsequent rounds of reports every year, by June 1.

The first biennial federal analyses of the drug market would start coming out in mid-2023.

Finer Points

Here are three more things to know about the pharmacy cost request for information.

1. The request has multiple contact people.

• IRS: Christopher Dellana.
• EBSA: Matthew Litton.
• CMS and HHS: Christina Whitefield.

2. Comments will be due 30 days after the official Federal Register publication data.

The Federal Register is preparing to publish the request for information document Wednesday.

The agencies are asking the public about implementation of the data collection, the data elements to be collected and the impact on plans and issuers.

In a list of questions for commenters, the agencies ask about payers’ experience with state drug cost reporting programs, any anticipated challenges in meeting the new federal reporting requirements and which types of plans that must file reports or may not have to file reports.

3. Officials want to try to simplify the paperwork.

Officials are asking if there’s a way to ease the workload by combining the new reporting requirement with other, existing reporting requirements.

Officials also want to hear about the role benefits consultants and outside plan administrators might play in preparing the drug cost reports.

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