As previously reported in December 2021, Section 204 of the Consolidated Appropriations Act, 2021 (“CAA”) requires plan sponsors of group health plans to submit information annually about prescription drugs and health care spending to Centers for Medicare and Medicaid Services (“CMS”) on behalf of the departments of Health and Human Services (“HHS”), Labor (“DOL”), and the Treasury (collectively, the “Departments”). The first deadline is December 27, 2022. CMS recently updated guidance related to this reporting requirement that provides some helpful clarification.
Employers with fully insured or self-funded (includes level funded) group health plans, including grandfathered plans, church plans subject to the Internal Revenue Code, and governmental plans. The term “group health plan” does not include excepted benefits such as onside clinics and accident-only policies. It also does not include account-based plans (e.g., HRAs or health FSAs).
As always, please contact your Total Benefit Solutions, Inc health insurance specialists with any questions or concerns at (215)355-2121.