CAA Prescription Drug Reporting: What You Need to Know

Employers must provide the following information to Aetna, which will be used to submit on behalf of the plan sponsor:

•    Average monthly premium paid by members

•    Average monthly premium paid by employer

•    Funding arrangement

•    Issuer name/legal entity

Aetna submitted all required reports for the 2022 reference year on behalf of all Small Group plan sponsors. If the plan sponsor did not complete the survey with the required premium information, then the report was released incomplete and did not include the required plan sponsor premium information. 

The plan sponsor will be responsible for ensuring the average monthly premium paid by members and by the employer are submitted directly to CMS through their HIOS portal by 6/1/23. Aetna is not responsible for any liability associated with an incomplete report due to missing information.

RxDC Plan Sponsor Data Collection Form

•    If a plan sponsor initially submits incorrect information, they can resubmit their form(s) with the updated information. Aetna will retrieve the most current form(s) submission on 4/1/2023. 

Deadline for submission is 4/1/2023

Fully Insured:

RXDC Average Monthly Percentage and Premium Reporting 
Deadline for submission is 3/24/2023

Broker Announcement

Prescription Drug Data Collection Reporting Provision

Self-Funded Group Announcement 

Starting in 2023, Anthem is requiring employers to provide information on the average monthly premium paid by the member and the employer in the Premium and Life Year (D1) reporting.

Your Next Steps:

1. Log in to Blue Access for Employers    or Register Here if you are new to BAE.

2. Click Prescription Drug Data Collection under Regulatory Data Collection on the BAE homepage to complete the form.

3. Enter your 2022 average monthly premiums paid by employer and members by April 13.

4. Click Submit. 

Blue Shield of California is collecting D1 Premium Contribution data as part of the Consolidated Appropriations Act, Section 204 (2021)– Prescription Drug Cost Reporting regulation, on behalf of our employer groups. 

To ensure group data is included in Blue Shield’s aggregate filing, groups will need to fill out the Blue Shield D1 intake form.

• Active groups will need to fill out the intake form available on Employer Connection upon logging in.
• Terminated groups will need to fill out this intake form, using their Blue Shield group ID and following web key: #24yr23.

The deadline to provide information is Friday, April 5, 2024 at 6:00PM (PST). 

Groups that miss this deadline will not be included in Blue Shield’s filing and may be subject to non-compliance if they do not report the required data directly to the CMS on their own. 

As a reminder, Blue Shield will submit D2 for all groups and D3-D8 for groups with prescription drug benefits under a Blue Shield health benefit plan. If a group does not have prescription drug benefits with Blue Shield, they should coordinate submission of D3-D8 with their pharmacy/prescription drug benefits carrier. Please see sections 6 and 7 of the CMS Instructions Manual for information on each of the reporting elements. 

Please note that data submitted is for the 2023 calendar year. For group plan sponsors whose benefit structure includes multiple groups (subgroups), the intake form must only be completed for the group, and not subgroup, under the main group ID. 

Here are a few reminders to prepare for submission:

• Brokers or other delegates of the group may fill out the intake form on behalf of the group. If you do not have access to the intake form for active groups via Employer Connection, please reach out to your group for delegate access.
• Only one individual may submit responses for a single group ID. Multiple individuals will not be able to submit information for a single group. Please coordinate submission with your group and any other delegates.
• A single broker or delegate may, however, submit a response for multiple groups.
• You may preview the intake form questions before submitting responses. Please submit the form only when all requested information is available.
• You may preview the intake form questions before submitting responses. Please submit the form only when all requested information is available.
• Once responses are submitted, only the submitter will have access to edit responses.
• Multiple submissions can be made until the deadline of April 5, 2024.
• Submitters will receive an email confirmation displaying their submitted responses and a link to edit responses. If you are completing the intake form on behalf of a group, please forward the confirmation email to the group.

We are requesting the following data from groups:

• Basic group information such as submitter email
• Healthcare premium percentage paid by employer for Small Business Groups and Large Groups that have pharmacy/prescription drug benefits with Blue Shield or,
• Total healthcare premium paid by employer and employee, for Large Groups that have pharmacy/prescription drug benefits with another carrier besides Blue Shield
• Total Premium Equivalent Amount (for self-funded ASO only, when applicable) - Total cost of providing and maintaining coverage, including claims costs, administrative costs, self-funded ASO and other TPA fees, and stop-loss premiums

Blue Shield is committed to supporting our groups in complying with health coverage related regulatory requirements.* Please support your groups by reminding them to submit necessary information before the deadline and helping submit information in the intake form, as needed. 

Please view the D1 Intake FAQs for more information. If you have any additional questions, please contact your Blue Shield representative.

Fully Insured: Carrier

To submit the June 1, 2023 report: 

Send an email to the address found in the communication sent from Cigna with the client name, account number, and average employee, versus employer percent of premium across the client’s medical, pharmacy, and behavioral coverage corresponding to their population with Cigna coverage by February 24, 2023. Include both Cigna and non-Cigna coverage.

Fully Insured: Carrier

Self-Funded: Carrier 

For the June 1, 2023 submission, which will represent the reporting year 2022, Cigna’s standard approach is to submit on our clients’ behalf.

Fully Insured: Carrier

Fully Insured: Carrier

 Pending carrier response

• Average Monthly Premium Paid by Member
• Average Monthly Premium Paid by Employer
• Form 5500 Plan Number (If Applicable)

Per the Centers for Medicare & Medicaid Services’ instructions, Sharp Health Plan is requesting the following information from our employers to complete the D1 Template for 2022 data:

• Average monthly premium paid by members

•Average monthly premium paid by employer

•Employer FAQ

New RxDC employer reporting intake form

Fully Insured: 

Sharp Health Plan will be submitting all elements of the 2022 RxDC filing by the June 1, 2023 due date; however, if an employer group does not provide the requested information by May 1, 2023, we will not be able to include that employer groups’ information in our filing. In that case, the employer group will be responsible for submitting all required data directly to the Centers for Medicare & Medicaid Services by June 1, 2023.

Self-Funded: N/A

Employer landing page

Broker landing page

Survey Link for Employers || Printable PDF

Survey Link for Employers

Fully Insured: Carrier