The Washington Report
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August 31, 2022
Note to Subscribers
While we do our best to provide timely updates, it is possible that the information shared in the newsletter may change after our publication deadline.
Legislative
Congress Adjourned for August Recess
The House and Senate are adjourned for the month of August, tentatively scheduled to return after the Labor Day holiday. (Please be aware that the congressional calendar can change at any time due to current events or bill consideration.)
Aon Publications
Employer Health Plans Face December 27 Deadline for Submitting Rx Data to CMS
Employers sponsoring group health plans must begin preparing for the first Prescription Drug Data Collection (RxDC), which is due on December 27, 2022. The RxDC submission includes medical, prescription drug, and premium/premium equivalent information and likely will require assistance from more than one vendor.
This Aon bulletin discusses:
- RxDC Submission Dates;
- Plans and Insurers Subject to the RxDC Submission Requirements;
- Elements of the RxDC Submission—Plan Files, Data Files, and Narrative Responses;
- Submitting the Plan Files, Data Files, and Narrative Responses to The Centers for Medicare & Medicaid Services (CMS); and
- Impact on Employers. This bulletin addresses certain compliance issues, including:
- Collecting and filing data from the pharmacy benefit manager and third-party administrator;
- Change in vendors;
- Plan year changes;
- Terminated plans;
- Non-federal governmental plans, church plans, and small plans;
- Entering into written agreements for fully insured plans; and
- Entering into written agreements for self-insured plans.
- Evolving Guidance
The Aon bulletin is available here.