Stay up to date on the latest federal mandates

Capitol Building in Washington DC

At BCBSND we’re continuing work to meet several ongoing federal mandates. Here’s a snapshot:

  • Fully insured groups, if you’ve not yet submitted the RxDC reporting form to your BCBSND account manager for 2022 reporting, please do so now. This is required by May 19th so BCBSND can meet the June 1 deadline.
  • We’ve reached out to self-funded employer groups who have action required for the 2022 Prescription Drug Data Collection reporting due June 1.
  • We will continue to provide a price comparison tool for 500 most common shoppable services. No action is required by employers.
  • We will publish machine-readable pricing files for fully insured employer groups. Self-funded employers can meet this mandate using these files.

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

As part of the RxDC mandate, we’re fulfilling the 2022 group reporting by the June 1 deadline.

The reporting includes:

  • Average monthly premium paid by employees and employers
    • Note: reporting for average monthly premium was waived for 2020 and 2021
  • Total healthcare spending broken down by type—hospital, primary 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 the 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, 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 and Labor and Treasury 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 and 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 these files.


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 to federal regulators information about air ambulance services provided to consumers.

Currently, 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.