2024 Prescription Drug Data Collection (RxDC) for CMS Reporting
The Consolidated Appropriations Act (CAA) requires health insurers and employer plans to report prescription drug data annually to CMS. These yearly reports on prescription drug use and costs are due by June 1st. However, many carriers will submit on your behalf. They require varying information and have differing due dates. Check your carrier’s due date and survey requirements below:
| Carrier | Due Date |
| Independence Blue Cross | 5/1/24 |
| AmeriHealth | 5/1/2024 |
| Cigna | No survey has been announced |
| Aetna | 4/12/24 |
| United Healthcare | 4/10/2024 |
| Horizon | Submitting On Client’s Behalf |
Medicare Changes May Affect Employer-Sponsored Group Health Plans
Recent changes to Medicare drug plans (like capped insulin costs) may make some employer-sponsored health plans lose their “creditable” status. This means Medicare-eligible employees on those plans might face a penalty if they don’t enroll in separate Medicare drug coverage.
Here’s what to know:
- Employers: You may need to update your plan options or communicate with employees, especially those nearing Medicare eligibility.
- Employees: If your plan loses “creditable” status, you may need to enroll in separate Medicare drug coverage to avoid penalties.
IRS Addresses Nutrition, Wellness, and General Health Expenses
The IRS clarifies that general health and wellness expenses cannot be reimbursed with pre-tax dollars from HSAs, FSAs, or HRAs. This includes gym memberships, weight-loss programs (unless treating a diagnosed disease), vitamins not prescribed for a specific condition, etc.
Employers offering these plans should ensure they only reimburse qualified medical expenses and that claims are properly documented. Beware of vendors promoting pre-tax wellness programs with doctor’s notes, as these may not qualify.
PA Now Offers Tax Relief for Dependent Care Expenses
Pennsylvania now exempts employer contributions to Dependent Care FSAs from state income tax (Act 34 of 2023). This means more money in your pocket if you use a Dependent Care FSA for qualified childcare or eldercare expenses. This applies retroactively to the beginning of 2023.
Employers: Update payroll systems to exclude these contributions from taxable income and communicate the tax benefit to your employees. Consider consulting a tax advisor for help implementing these changes.
Compliance Corner: RxDC Explained
- Who reports: Insurance companies and employer-based health plans
- What they report: Prescription drug spending, healthcare service spending, top prescribed drugs, drug rebates, premiums, and cost-sharing by patients.
- Why they report: To help understand trends in drug and healthcare spending, impact of drug rebates, and promote transparency in drug pricing.
- What is public: Findings on drug pricing trends and impact of rebates on patient costs.
Rob is an employee benefits expert with over 25 years of experience. He is the founder and principal of Precision Benefits Group, a leading provider of corporate benefits plans. He is a member of the Philadelphia Business Journal Leadership Trust and regularly contributes to the publication.