Hi all, I wanted to get together a quick article as we’re entering into what I call the springtime government reporting season.
Seems like every few years the government likes to layer on additional requirements for businesses to report on different aspects of HR & benefits. When the Consolidated Appropriations Act of 2021 passed (often referred to as CAA) another new reporting requirement was developed. It’s a mixed bag of reporting, as there is data that employers have to provide (normally to their insurance providers or third-party administrators), and then that data gets combined with a ton of pharmacy data that the insurer/TPA sends up the reports to the Center for Medicare and Medicaid Services.
Why in the world does all this matter?
Well, being the “reporting season” as I mentioned above, we’re already working with UHC and our clients who use or have used UHC to gather the data that UHC needs to get their information submitted. UHC sent their initial requests here in Texas in early February and clients have until March 31st to get the information submitted so that UHC can meet their deadlines. We know BCBS of TX is supposed to start their data requests in mid-March and I’m sure others will be on the horizon as well.
A few key points that we wanted to make to everyone, regardless of who your insurance company is.
1. LET YOUR INSURANCE COMPANY OR TPA HANDLE THIS FOR YOU.
They already have the majority of the pharmacy and health plan data that has to be submitted on the report. They only need a few things from you to fill in what is missing.
We say this because it is much easier and there would be little to no hard costs involved for your company to pass your insurance provider the info they need and to let them handle it. To go about it on your own, especially if you’re a smaller business would be very time-consuming and in many cases super expensive. There are of course companies out there that will charge you to handle this reporting, but everyone we have seen charges an arm and a leg. Going this route just creates extra work on you to pull the data needed from your insurance provider, who if you remember, will handle this for you already at little to no additional cost. We all know, especially in small groups, it is very difficult to claim information, but the level of detail that is required in this situation, I believe, with most insurance companies would be almost impossible to get your hands on. Eliminate any future potential headaches and don’t go down this path, please.
2. GET YOUR INSURANCE PROVIDER THE INFORMATION THEY NEED BY THEIR DEADLINE.
You don’t want to miss this and be forced to find an outside party to handle it for you simply because you missed a deadline.
3. WHAT INFORMATION NEEDS TO BE REPORTED?
Let’s talk about the data real quick. In most cases, there are a few reports that you can run either out of your payroll system OR out of your bookkeeping system (maybe both) that should be able to get you everything you need to report back to your insurance provider.
For most of our clients who are using an online enrollment system, we can go in and run reports that give us almost 99% of the information, so for the clients who have wanted the help, we’ve gone in, run the reports, gotten their approval and in many cases gone ahead and submitted the information back to UHC.
I know BCBS will give us similar abilities where we can go in and submit on behalf of a client which is nice. We all know business owners are busy and aren’t trying to do all this extra administrative work, so this is one of the areas where we’re happy to help.
The information that the insurance companies will be asking you as the business is simply the average monthly spend from the company standpoint on health insurance as well as the average employee spend on health insurance. When we say the average month employer spend, this is not the amount on your invoice.
The insurance companies do not track what your company is covering out of your overall totals as compared to what the employees are paying for through payroll deduction, so that’s the breakouts they are looking for. They have everything else. Let them run with the reports, please. 😊
Here’s a quick link to the CMS website where it discusses at a high-level what this reporting is about and its purpose as well a very informative link from UHC that talks about the reporting in a little more detail.
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CMS Link – https://www.cms.gov/marketplace/about/oversight/other-insurance-UIHC – protections/prescription-drug-data-collection-rxdc
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UHC Link – https://www.uhc.com/united-for-reform/health-reform-provisions/pharmacy-benefits-and-cost-reporting
The government is supposed to be using this data to help research increases related to drug costs and gives the impression that they will someday take action on this, but don’t hold your breath. As we all know the government does not move fast. I personally wish they would exclude all small businesses that are fully insured and/or level funded from all of these reporting requirements. The insurance companies and TPA’s have all the relevant data that the government is looking for and like I’ve said a million times before, every new reporting requirement the government comes up with, regardless of its intent, is a tax on business owners. For large self-funded companies who actually create their own plans and formularies, great, ok, make them self-report but for the smaller businesses who don’t get any say in what drugs are or are not on the formulary, let’s leave them alone. If anyone needs help in this area, please let us know. Our main goal is to help every client we have to get the information that’s needed to their own insurance provider so the time and money they have to spend on this reporting requirement is kept at a minimum.
Thanks for the read. Ryan
