On December 23, 2022, FAQs were released outlining late-breaking RxDC Reporting Relief. Of note -

1. For the 2020 and 2021 data submissions that are due by December 27, 2022, the Departments will not take enforcement action with respect to any plan or issuer that uses a good faith, reasonable interpretation of the regulations and the Prescription Drug Data Collection (RxDC) Reporting Instructions in making its submission.
2. The Departments are also providing a submission grace period through January 31, 2023, and will not consider a plan or issuer to be out of compliance with these requirements provided that a good faith submission of 2020 and 2021 data is made on or before that date.

In addition, several other clarifications and flexibilities are described including with respect to multiple submissions by the same and multiple reporting entities, submission of premium and life years data via email, and the reporting of amounts not applied to deductibles or out-of-pocket maximums. The Departments also noted that additional guidance may be released in advance of future reporting deadlines.

Plan administrators should work with vendors and counsel to determine whether the new FAQs impact the plan’s RxDC reporting.

The KMK Law Employee Benefits & Executive Compensation Group is available to assist with these and other issues.

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