CAA Mandate

Man using a calculator and looking at bar graphs

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

  • BCBSND fully insured groups should submit the RxDC reporting form to their BCBSND account manager
  • BCBSND has reached out to self-funded employer groups that have action required for the Prescription Drug Data Collection for 2022 reporting
  • BCBSND will continue to provide a price comparison tool for the 500 most common shoppable services. No action is required by employers.
  • BCBSND will publish machine readable pricing files for fully insured employer groups. Self-funded employers 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 2022 calendar year reporting for groups by the deadline of June 1.

This reporting includes:

  • Average monthly premium paid by employees and employers
  • Note: Reporting for average monthly premium has been waived for 2020 & 2021
  • Total health care 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 and fully insured groups to complete this submission.

  • A BCBSND representative has been in contact with any self-funded group that needs to provide information
  • Fully insured groups, please submit the RxDC reporting form to your BCBSND account manager

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 continue to support this tool and make further enhancements as we get closer to releasing the tool with all shoppable services available January 1, 2024.

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 includes:

  • 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 employers can meet this mandate using BCBSND-provided files by linking the following page on their public facing website: https://mrfdata.hmhs.com.

No Surprises Act (NSA) Air Ambulance Data Collection (AADC)

The Department of Health and Human Services is conducting an Air Ambulance Data Collection (AADC). As part of section 106 of the No Surprises Act, health plans will be required to submit information to federal regulators about air ambulance services provided to consumers.

At this time, final rules are still being defined. BCBSND will continue to monitor for final ruling and provide information on what the data collection piece will require of employer groups.