Prescription Data Collection reporting or “RxDC” is one of the more recent compliance requirements that falls on the responsibility of employers offering health benefits to their employees. For the past few years, there has been the safety of “good faith” relief in place as the process and regulations were rolled out from 2020 through 2022. There is currently no good faith relief in place from plan year 2023 moving forward.
The data collection and submission process can vary the full gamut between extremely complicated to relatively simple depending on the structure of the health plan and the services offered by vendors in place.
This article focuses specifically on fully insured health plans administered by the Blue Cross Blue Shield companies that fall under the Healthcare Service Corporation family of companies that includes the offerings of Blue Cross Blue Shield in Texas, Oklahoma, Illinois, Montana, and New Mexico. If you need details on the Blue Balance Funded (level-funded health plans) or how to comply with your Blue Cross ASO or self-insured health plan please reach out to our team for those specific details.
As an employer under the Blue Cross Blue Shield health plans with HCSC, the burden of RxDC reporting is minimized. Blue Cross ultimately does all the final data transmissions in the HIOS system with the Center for Medicare and Medicaid Services for you. However, Blue Cross only has a portion of the information they need. Due to this limitation, each March, you as an employer need to help out and help Blue Cross complete the data collection portion that pertains to your company.
Please note, if Blue Cross doesn’t get the data they need in a timely manner, your responsibility as an employer shifts from relatively simple to extremely complex really fast. The moral of the story is to follow their instructions and get them the information they need timely.
So, what is being asked of you as the employer?
The data is pretty simple. Blue Cross already knows the total dollar amount you have paid them each month. What they don’t know is the breakdown of employee money vs. employer money each month of your plan year.
The data you need to gather is the average of your monthly employee contributions and the average of your monthly employer contributions. This may be very simple if you don’t have much turnover, and your health plan year coincides with the calendar year. But, the ability to gather those calculations gets really murky in the real world once you factor in the variables of new hires, dependent enrollments, mid-year plan changes, multiple health plan options, and mid-year health insurance carrier changes.
One quick note, it is important to pay close attention if you had Blue Cross Health Plan coverage for less than 12 months during the prior calendar year. If this occurs, you will need to make 2 submissions, 1 per health insurance provider.
If you are using an online benefits administration portal like Employee Navigator, which is the tool we support for the vast majority of our clients, that complexity gets reduced greatly to a simple report and a few basic spreadsheet calculations. Here is how to run that report and grab the data you need to input.
Video Overview:
Step-by-Step Overview:
1. Log into your Employee Navigator account as an HR or Admin user.
3.When selecting the parameters, choose the months from January through December of the prior calendar year.
3.a.If you had the same insurance carrier for all 12 months, even if your plan was renewed mid-year, this report is good for all 12 months, just make sure to toggle on all of the medical plan options offered through that insurance vendor that existed during that time frame.
3.b. If you had a mid-year insurance carrier change, you can keep the same date range but only toggle on the appropriate medical plans from the vendor you need to supply the accurate information. You’ll need to stop and duplicate this effort for the other vendor that occurred in that same calendar and save that report somewhere handy as you’ll likely need to provide them this same data.
4. After this is complete, you need to perform 2 quick mathematical operations in your spreadsheet.
4.a. Add a Sum Total to each of the 3 fields (Employee Cost, Employer Cost, Plan Cost)
4.b. For Blue Cross, you’ll then need to average that total cost by the number of months their plan was in place. Again, if they were in place all calendar year, divide the totals by 12. If you experienced a change in vendors, then divide that total cost by the appropriate number of months that Blue Cross was in place.
5. You now have the numbers that you need to provide to Blue Cross.
6. Log into your Blue Cross for Employer portal.
7. Navigate to the View Regulatory Data menu and choose “View/Update Prescription Drug Data Collection” from the dropdown menu.
8. In this section, input those averages and hit the “submit” button.