The Departments of Labor, Treasury, and Health and Human Services (the Departments) issued reporting relief for health plans and issuers facing difficulty meeting the December 27th, 2022, deadline of reporting prescription drug and health care spending information.
The Consolidated Appropriations Act, 2021, (CAA) requires that health plans and issuers report, on an annual basis, certain prescription drug and health care spending information. The first reporting (for 2020 and 2021) was originally due in December 2021 but was delayed to December 27, 2022. The reporting has proved to be a challenge for many plan sponsors and issuers.
As such, the Departments announced two important pieces of relief:
- The Departments will not take enforcement action against a plan or issuer that uses a good faith, reasonable interpretation of the regulations and the reporting instructions in making its submission for the 2020 and 2021 plan years.
- The Departments will permit a grace period until January 31, 2023 for the 2020 and 2021 submissions due on December 27th.
The Departments have also addressed a few issues regarding the filing requirements, including the data aggregation rules and optional reporting on vaccines. They also clarified the permissibility of multiple submissions (by one reporting entity on behalf of more than one plan or issuer) and multiple reporting entities (for the same plan or issuer). The Departments will allow certain limited information to be reported via email. The FAQs can be found at: https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-56
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