Prescription Drug Data Collection (RxDC) requires health plans to submit annual data on premiums, enrollment, health care and prescription drug spending, and rebates to CMS. With that information often spread across internal systems and outside vendors, preparing a complete submission takes coordination well before the June 1 deadline.
In this episode of Regulatory Joe, ClearFile President Joe Boyle explains how RxDC reporting works, where health plans can encounter challenges gathering the required data and how to keep the annual submission on track.
Understanding RxDC Plan Lists, Data Files and Narratives
RxDC reporting is organized into three main components:
- Plan lists: Identify the health plans included in the submission.
- Data files: Contain the required premium, enrollment, health care spending, prescription drug utilization and rebate information.
- Narrative: Explains certain reporting methods and provides additional information required by CMS.
CMS releases updated reporting instructions and standardized templates each year. However, not every template necessarily applies to every organization.
Health plans need to determine which templates apply based on the populations they serve and the drugs they administer. Requirements vary by template, and the D3 through D8 prescription drug files can involve particularly complex data collection and calculations.
Identifying the applicable templates early gives filing teams a solid starting point for determining which information they need, where to find it and what must be validated ahead of submission.
How Health Plans Collect Data for RxDC Reporting
The information needed to complete an RxDC template may come from several sources, even within the same file.
For instance, a health plan may have membership data available in its internal data warehouse but need additional information from an outside enrollment or billing vendor to complete its premium and life years reporting. Other files may require data from the plan’s PBM, formulary partner or other administrators.
Whoever is responsible for each HIOS submission needs to confirm that the correct templates are included, the required information is complete and any inapplicable templates are handled according to CMS instructions.
RxDC Reporting Checklist for Health Plans
At ClearFile, we recommend establishing a reporting process early on, with a clear roadmap and checks and balances for each stage.
- Review the current CMS guidance. Identify applicable templates, reporting instructions and validation requirements. CMS also publishes a checklist that can help guide the review.
- Map your data sources. Determine which information is available internally, what needs to come from vendors and who is responsible for collecting and validating each piece.
- Confirm HIOS access early. Existing users may need approval through their organization’s ORA, while new users can face additional setup and background-check requirements.
- Validate the completed submission. Confirm that required templates are populated correctly and that inapplicable templates haven’t been included.
- Document the process. Maintain a central repository with supporting information, completed files and standard operating procedures so the team can respond if CMS has questions.
The June 1 deadline can approach quickly once teams begin gathering information and resolving data gaps. Establishing these processes ahead of time helps health plans manage the work more consistently each reporting year.
Watch the full episode of Regulatory Joe for a deeper look at RxDC reporting requirements and how health plans can prepare for the annual submission.
