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The No Surprises Act’s transparency provisions require employer-sponsored health plans and issuers to provide information regarding health care spending and prescription drugs to the federal government. The reporting process is called the prescription drug data collection or RxDC report for short. The RxDC report was required to be submitted by December 27, 2022.
Submission Grace Period
The Departments of Labor, Health and Human Services and the Treasury (Departments) stated in an FAQ that they will not take any enforcement action against a plan or issuer that makes a good faith, reasonable interpretation of the regulations and reporting instructions in making their 2020 and 2021 data submissions by December 27, 2022.
The Departments are also providing a submission grace period through January 31, 2023. They will not consider a plan or issuer out of compliance provided that a good faith submission of 2020 and 2021 data is made on or before that date.
Employer Compliance Steps
Most employers will rely on their carriers, TPAs, or third parties to report their prescription drugs costs by the deadline. Employers may need to update their written agreements with these parties to reflect that responsibility and confirm timely reports will be submitted. Download the bulletin for more details.
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