America's Benefit Specialist August/September 2023
circumstances, the employer just needed to create and submit the P2 and D1 reports. It is important for employers to ask specific questions to their carrier, TPA, broker, etc., about who is creating and submitting what reports. They should have direct communication by April of 2024 with their providers/advisors to ensure everyone understands their roles and responsibilities in the reporting process. Additionally, if they have any questions or issues with HIOS or the reports, communicate with CMS early in the report ing period. For many, getting set up in the HIOS system was the biggest struggle this past reporting period. 3. Plan ahead for deadlines . The reporting deadline for RxDC is June 1, so it’s essential for your clients to plan ahead and allocate sufficient time and resources for data collection, report creation and submission. They should put a reminder on their calendar for January-February to look for communication from their carrier, TPA or broker, who likely will send out a “survey” asking for information they need to complete the reporting on the client’s behalf. If a client is submitting for themself, they need to ensure their access and setup in HIOS is done in early April. 4. Stay informed of updates and changes . RxDC reporting is not going away! Keep abreast of any updates, changes, or clarifications from CMS or the HIOS system regarding reporting requirements. CMS will learn a lot following the 2020, 2021 and 2022 reporting cycles, and we expect the RxDC reporting requirements to evolve. Subscribe to relevant newsletters, attend webinars and actively engage with industry forums and professional associations to stay informed about the evolving landscape of RxDC reporting. REGTAP and the CMS RxDC websites are great resources. Don’t ignore or gloss over information provided by carriers and other providers. 5. Seek expert guidance if needed . If you find the reporting process particularly challenging or have limited experi ence in this area, consider seeking guidance from experts in compliance reporting, such as consultants or special ized compliance-reporting providers. There are service providers that can create and submit the RxDC reports you need for a small fee. That fee might be an acceptable exchange for peace of mind that the reporting is handled correctly. Their expertise can help streamline the process and ensure compliance with CMS requirements. Additionally, it’s worth mentioning that the RxDC report ing requirement is separate from other compliance-re porting requirements, such as the Medicaid Drug Rebate Program or the reporting obligations under ERISA, HIPAA or the Affordable Care Act. Each program or requirement may have its own distinct reporting obligations and guidelines. By incorporating these lessons learned into your RxDC reporting to CMS and the HIOS system, your clients can prevent the last-minute stress to get their RxDC reporting completed and submitted while reducing time and effort.
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