Staying Compliant with Federal Mandates—What You Need to Know

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We continuously work to meet ongoing federal mandates, and we're committed to keeping you informed and supporting you in meeting these requirements.

Important Deadline: Submit Your RxDC Reporting Form to BCBSND by May 19

Fully insured groups are required to submit the 2022 RxDC reporting form to their BCBSND account manager by May 19. If we do not receive the information by May 19, you will need to complete the P2 and D1 with contribution information by June 1 to CMS. To find information on how to perform these filings on your own, please visit CMS Prescription Drug Data Collection.

We have already reached out to self-funded employer groups that require action for the Prescription Drug Data Collection for 2022 reporting, which is due June 1 to CMS.

BCBSND will continue to provide a price comparison tool for the 500 most common shoppable services. No action is required by employers.

Additionally, we 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 June 1. This reporting includes various aspects, such as the average monthly premium paid by employees and employers, total health care spending breakdown by type (hospital care, primary care and specialty care), prescription drug spending by enrollees versus employers and insurers, and much more. It's all about transparency and keeping everyone in the know.

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

This rule requires health plans to create a patient-facing price comparison tool, allowing individuals to make more informed decisions about their care. We fully support this tool and are continuously working to enhance it. We aim to release the tool with all shoppable services available by 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 one 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, which requires health plans to make publicly available machine-readable files (MRF) that contain specific pricing information.

These MRFs include negotiated rates for covered services with in-network providers, as well as historical payments 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 this data collection as part of section 106 of the No Surprises Act. Its purpose is to gather information from health plans regarding air ambulance services provided to consumers.

While the final rules for the AADC are still being defined, rest assured BCBSND is closely monitoring the situation. We'll keep you updated and provide information on what the data collection process will require from employer groups.

Stay tuned for more updates as we navigate these federal mandates together.