BCBSND and Employer Mandate Compliance Update

Female patient handing a prescription to a pharmacist

Blue Cross Blue Shield of North Dakota (BCBSND) continues to work to meet several ongoing federal mandates and wanted to provide an update.

  • BCBSND will submit require Prescription Drug Data Collection files on behalf of employer groups, including self-funded employers, to CMS by December 27.
  • BCBSND will provide a price comparison tool for 500 most common shoppable services by January 1, 2023. No action is required by employers.
  • BCBSND will publish machine readable pricing files for fully insured employer groups. Self-funded employer can meet this mandate using BCBSND provided files by linking the following page on their public facing website: https://mrfdata.hmhs.com.

Consolidated Appropriations Act (CAA) Prescription Drug Data Collection (RxDC)

As part of the RxDC mandate, BCBSND is working to fulfill the 2020 and 2021 calendar year reporting for groups by the deadline of December 27.

This reporting includes:

  • Average monthly premium paid by employees and employers.
    • Note: reporting for average monthly premium has been waived for 2020 & 2021.
  • Total healthcare spending broken down by type (hospital care, primary care, and specialty care).
  • Prescription drug spending by enrollees versus employers and insurers.
  • 50 most frequently dispensed brand prescription drugs.
  • 50 costliest prescription drugs by annual spending.
  • 50 prescription drugs with the greatest increase in plan or coverage expenditures from the previous year.
  • Prescription drug rebates and fees must be reported with some specificity.
  • Premium and life-years.

Who does this apply to

Fully insured group health plans, self-funded group health plans and individual policies – including all grandfathered plans.

Employer Action Required

BCBSND will submit reports to CMS on behalf of employers, including self-funded groups. In a limited number of instances, BCBSND will need information from self-funded groups to complete the submission. A BCBSND representative has already been in contact with any group that needs to provide information. If your group has not been contacted, no action is needed.  

Transparency in Coverage Rule Price Comparison Tool

The Departments of Health and Human Services, Labor and Treasury previously finalized a Transparency in Coverage rule that requires health plans to create a patient facing price comparison tool. The intent of this regulation is to provide health care pricing information for individuals to make more informed decisions about their care.

BCBSND will provide a self-service price comparison tool that will be available online through the member portal. Individuals call also request pricing by calling the contact center. As of January 1, 2023, your employees will be able to compare pricing for the 500 most common shoppable services.

Who does this apply to

Fully insured health plans, self-funded health plans and individual policies with estimated costs.

Employer Action Required

None. BCBSND will provide a cost price transparency tool to meet this mandate including for self-funded employer groups.

Transparency in Coverage Rule Machine Readable Files

The Departments of Health and Human Services, Labor and Treasury previously finalized a Transparency in Coverage rule that requires health plans to post publicly available machine-readable files (MRF) containing certain pricing information.

MRF include:

  • Negotiated rates for covered services for in-network providers
  • Historical payments to and charges from out-of-network providers for covered items and services

Who does this apply to

Fully insured group health plans, self-funded group health plans and individual policies, with the exception that this mandate does not apply to grandfathered health plans.

Employer Action Required

BCBSND will publish files for fully insured employer groups. Self-funded employer can meet this mandate using BCBSND provided files by linking the following page on their public facing website: https://mrfdata.hmhs.com.