Under Section 4002 of the Support for Patients and Communities Act reporting prescription drug coverage information will no longer be optional under Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 beginning January 1, 2020.

 

Responsible Reporting Entities (Employers through their Group Health Plans, Self-Insured Plans and their Third Party Administrators) will be required to report primary prescription drug coverage information beginning in 2020 in addition to the current mandate to provide quarterly reports of Medicare beneficiaries (or his/her spouse)  covered by the employer’s group health plan.

 

The Centers for Medicare & Medicaid Services (“CMS”) will require Reporting Entities to add  several additional data elements to their Section 111 reports about their drug coverage plan in their first assigned reporting period after 1 January 2020..

 

As a consequence of the change, the requirement to report may fall to the insurer’s or self-insured’s Pharmacy Benefits Manager (PBM).  The PBM is the Reporting Entity in situations where they are fiscally responsible for adjudicating and paying the claims.  During a recent teleconference CMS recommended that insurers and their TPAs reach out to their PBMs to ensure they aware of their requirement to report.

 

Medicare Consul Services (MCS) provides Section 111 MMSEA software and services for Group Healthcare and Drug Coverage Reporting.  Please feel free to contact us if you have questions or require a solution to meet your Reporting Entity requirements.