Reporting on Pharmacy Benefits and Drug Costs under CAA

The Consolidated Appropriations Act, 2021 (CAA) Section 204 – Reporting on Pharmacy Benefits and Drug Costs

Under the Consolidated Appropriations Act (CAA), health insurers offering group or individual health coverage and self-funded (ASO) group health plans are required to report data annually on prescription drugs and health care spending to the Departments of Health and Human Services (HHS), Labor (DOL) and Treasury (USDT).

What you need to know

  • This year, the data must be submitted by December 27, 2022, through a web portal that is being set up by the Centers for Medicare & Medicaid Services (CMS). The December 27, 2022, report must include data from January 1, 2020 through December 31, 2021.
  • Reports will be created and sent directly to CMS by Carriers and Pharmacy Benefit Managers. Plans are not required to assist or provide any information regarding pharmacy benefits and drug costs.
  • Beginning in 2023, these reports will be required by June 1 each year. Reports submitted for June 1, 2023, require the 2022 data.
    The health care spending data and pharmacy data do not have to be aggregated into one submission. Carriers and Pharmacy Benefit Managers will report to CMS separately.
  • The reporting will be aggregated at the issuer/TPA/state/market level, rather than separately for each plan. The guidance provides uniform standards and definitions, including standards for identifying prescription drugs regardless of the dosage strength, package size or mode of delivery so HHS, DOL and USDT can conduct meaningful data analysis and identify prescription drug trends.