Annual RxDC Reporting Deadline Drawing Near

May 2, 2024

Prefer to listen instead of read? No problem! Listen to the blog post at any time by clicking here.   The Consolidated Appropriations Act of 2021 established a new data collection requirement for employers of all sizes and funding structures, where such entities must now submit annual prescription drug data collection (RxDC) reports on their plan’s prescription drug and health care spending to the Centers for Medicare and Medicaid Services (CMS). The calendar year 2023 reports are due by June 1, 2024. We encourage employers to ensure that these reports are submitted accurately and timely, as the “good faith” compliance standard applied to the initial 2020 and 2021 RxDC filings is no longer available.  RxDC reports from employer group health plans must include a file of general plan information (P2), details about the plan’s enrollment information and allocation of premium dollars (D1), and seven data files (D2-D8) that primarily reflect statistics about prescription drug usage and medical claims data.  Narrative files explaining the data contained in the D1-D8 reports are also required. Of note, RxDC reports are not required for retiree-only plans, excepted benefits, or account-based plans like HRAs, but they are required for all traditional group health plans in all U.S. states and territories.  Because employers do not typically have access to the claims data required to prepare D2-D8 files and their accompanying narratives, employers are permitted to have multiple vendors submit data files on behalf of their plan. Plan sponsors will likely rely on as many as three vendors to satisfy these complex reporting requirements:  PBMs will generally complete D3-D8 files (which include pharmacy data files and related data files).  Carriers and TPAs will generally complete and submit D2 files (which include health care spending files).  Depending on the circumstances, employers or their compliance vendors, carriers, or TPAs will generally complete and submit D1 files (including information about plan enrollment and premium data).  Each separate filing must also be accompanied by a P2 cover letter-type filing identifying the plan(s) included in that filing.  The 2023 RxDC instructions include a notable difference from previous years in that this is the first year that CMS will enforce the previously suspended aggregation restriction. This restriction prohibits the D1 medical premium and life years data and the D3-D8 pharmacy benefit data from being reported at a “less granular level” than the D2 medical benefit data. In other words, if the D2 is submitted on a plan-level basis, the D1 and D3-D8 files must be submitted similarly; they cannot be submitted by market segment unless the D2 file is also provided on a market segment-level basis. The D1 and D3-D8 files may be submitted at a more granular level than the D2 file, meaning that these reports can be created on a plan-level basis even if D2 reflects market segment-level information.  The most significant challenge many employers face for RxDC reports is identifying a solution for submitting the D1 data, which needs to be filed along with its own P2. Even though the P2 plan information and D1 premium data files are comprised primarily of information employers should know about the health plan they have offered, there are complex requirements within the P2 and D1 file specifications, and it takes weeks to obtain the account with CMS’s Health Insurance Oversight System (HIOS) required for their submission. As a result, most employers will need assistance from a vendor or compliance expert to create and submit these reports through HIOS.  Employers working with a health insurer, TPA, or PBM to submit D1 files on their behalf will likely encounter tight deadlines to provide their vendor employer-specific information for these filings.  In some cases, these deadlines may have already passed; in others, a plan’s vendor may refuse to help submit D1 data. The reluctance to help and tight deadlines exist because carriers, TPAs, and PBMs must focus on the “heavy lift” that submission of D2-D8 claims files requires.   For employers whose carrier/TPA/PBM is unwilling or unable to submit D1 on their behalf or for those who have missed their vendor’s deadline, MZQ Consulting is available to prepare and submit D1 and P2 files for your organization. Click here to get more information.  

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The ROI of Empathy: Unveiling the Value of Always-On Employee Care

April 25, 2024

Prefer to listen instead of read? No problem! Listen to the blog post at any time by clicking here.   Empathy can sometimes take a backseat to productivity and efficiency. However, recent insights suggest that nurturing an always-on approach to employee care isn’t just good ethics—it’s smart business. This deep dive unveils the return on investment (ROI) companies can achieve by genuinely caring for their teams.  The essence of always-on care  Imagine a work environment where wellbeing is not merely an afterthought but an aspect of company culture. Always-on care embodies this vision, providing support to employees across all life’s phases—both professional and personal. It’s a holistic approach, encompassing mental health support, financial wellness, professional development, and a healthy work-life balance.

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Final Rules Issued on Employer-Sponsored Indemnity Insurance

April 18, 2024

Prefer to listen instead of read? No problem! Listen to the blog post at any time by clicking here.   On March 28, 2024, the Departments of Health and Human Services (HHS), Labor, and the Treasury (collectively, the Departments) released final rules governing employer-sponsored indemnity insurance. This type of medical coverage is designed to provide limited-scope benefits and is therefore exempt from certain legal requirements that otherwise apply to major medical plans. As such, indemnity insurance is strictly regulated to ensure that consumers and employees understand what they are buying when they enroll in these plans. Many employers offer hospital or other fixed indemnity insurance products designed to qualify as “excepted benefits,” meaning that they do not have to comply with the Affordable Care Act’s coverage mandates. Under these arrangements, the insurance policy must pay a fixed dollar amount per day (or per other time period) for a hospitalization or illness, regardless of the amount of expenses incurred.  These plans are traditionally used as a form of income replacement upon the occurrence of a health-related event. They are not, nor have they ever been, a substitute for comprehensive coverage. Consumers have the option of using the fixed cash benefit as they wish, whether it be to cover out-of-pocket expenses not covered by comprehensive coverage, or to defray non-medical expenses such as rent or mortgage.  Notably, the guidance emphasizes that employer-sponsored indemnity plans are not permitted to reimburse participants on a per service basis, such as per doctor visit or surgical procedure. Thus, indemnity plans cannot provide benefits in varying amounts based on the type of procedure or item, such as the type of surgery being performed, or the type of prescription drug provided.  In proposed regulations issued last year, the Departments expressed concern regarding employers that offer these plans alongside medical plans that provide minimum essential coverage, but not minimum value (e.g., preventive-care only plans), and suggested prohibiting such arrangements. Specifically, the Departments were concerned that these arrangements are intended to circumvent the Federal consumer protections and requirements for comprehensive coverage that otherwise apply to employer-sponsored plans. Though the proposed prohibition was not adopted in the final rule, the Departments have indicated that they will continue to study the issue, noting that “[n]o inference should be drawn from the decision not to finalize the proposed . . . example[s].”  The Departments did finalize requirements relating to strict new notices that must be provided to employees who are offered indemnity insurance. These notices point out the differences between fixed indemnity excepted benefits coverage and comprehensive coverage. For plan years beginning on or after January 1, 2025, any employer offering hospital indemnity or other fixed indemnity coverage will need to include the notice below in at least 14-point font on the first page (in either paper or electronic form, including on a website) of any marketing, application, and enrollment materials that are provided to participants.   Please feel free to reach out to MZQ Consulting with any questions.

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HHS Delivers Reports to Congress on HIPAA Compliance 

April 11, 2024

Prefer to listen instead of read? No problem! Listen to the blog post at any time by clicking here.    On February 14th, 2024, the Department of Health & Human…

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The Integrity Check: A Leader’s Guide to Authenticity

April 4, 2024

It’s all too easy to articulate a vision of the ideal company culture—emphasizing values like work-life balance, respect, and open communication. However, as many of us find out, the real challenge lies not in defining these values but in living them, especially when the pressure mounts. Whether it’s sending emails late into the night or working through weekends, these moments test our commitment to the very culture we advocate for. Ironically, in our bid to lead by example, we might set a standard that contradicts our preached values. This dissonance affects personal wellbeing and can erode trust within your team as they struggle to reconcile what you promote with the behaviors you exhibit. It’s a reminder that leadership is as much about introspection and self-regulation as it is about guiding others. To help maintain alignment between your actions and your stated values, consider this monthly reflection exercise. It can be a personal audit, ensuring you stay true to your vision and lead with integrity.

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Navigating the Future: Advancements in Employee Wellness Programs

March 28, 2024

Prefer to listen instead of read? No problem! Listen to the blog post at any time by clicking here.   Employee wellness is not what it used to be, and that’s a good thing. Gone are the days of traditional approaches like gym memberships and nutrition workshops. Today’s workplace wellness programs are as diverse as the workforce itself, spanning the spectrum from physical to emotional and social wellbeing. Many employees, especially those who are now hybrid or online, see wellness programs as a way for organizations to listen to their needs as individuals. They now include aspects of mental and emotional wellbeing, social interaction, and financial health, reflecting an understanding that wellbeing is complex. With a focus on individual cultures and personal needs, these programs cater to employees’ unique work-life balance requirements.

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