CAA Rx Reporting Regulation

What is the CAA Rx Reporting Regulation?

The CAA Rx reporting regulation is part of the Consolidated Appropriations Act (2021), requiring all self-funded and fully insured health plan plans to report specific data about prescription drug pricing and rebates plus health care spending to the federal government. Reporting is due annually in June. 

Who needs to comply with this regulation?

Sana and our Pharmacy Benefits Manager (PBM), SmithRx, will take care of all reporting requirements for active periods each year on your behalf.

Sana will submit reporting to the Centers for Medicare & Medicaid Services (CMS) on behalf of all plans active during the calendar year for which reporting is due.

  • We submit P2 (Plan Files) and D1 and D2 (Data Files) on your behalf. 
  • Data Files D3-D8 are submitted by our PBM. 

What information is needed?

We don’t need any information from groups at this time.  We have everything we need to submit this report on your behalf.

Does Sana charge groups for this service? 

This service is already included in your administrative fees.

What proof will be provided once this is complete?

CMS doesn't have a way to track submissions on a group level, but you can feel free to reach out to our Customer Success Team if you have any doubt your report was submitted on time. We're committed to keeping up compliance for all of our groups.

Does Sana provide reporting for time periods when groups are on other plans?

We only file for time periods for which we and our partner PBMs are the vendors. We provide this service regardless of whether or not we are the current vendor.  Groups will only have to worry about reporting for the months they are not with Sana.

Have questions? We've got you covered.