What is the CAA Rx Reporting Regulation?
This regulation is part of the Consolidated Appropriations Act (2021). It requires all plans to report specific data about prescription drug pricing and rebates plus health care spending to the federal government. This is due January 31, 2023 for 2020 and 2021 plans and is due annually in June for calendar years following the initial submission. Sana will take care of all reporting requirements for active periods each year on your behalf.
Who needs to comply with this regulation?
All self-funded and fully insured health plans are part of these regulations. This means all plans offered by Sana will require this reporting on an annual basis. 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 the Pharmacy Benefits Manager (PBM) for the reference year. For plans starting on or after July 1, 2020, this will be SmithRx. For plans prior, this will be Elixir (fka MedTrakRx). Some groups will have reporting from both PBMs for the same reference year.
What information is needed?
We don’t need any information from groups at this time. We have everything we need to submit this reporting 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.