Q4 2022 Essentials for Plan Sponsors
Here are some key factors and deadlines to keep in mind for Q4 2022.
December 27, 2022 - Prescription Drug Data Collection (RxDC) Reporting Is Due
The RxDC reporting requirement requires employers to submit prescription drug data to the Department of Health and Human Services (HHS), the Department of Treasury, and the Department of Labor (DOL). The deadline is December 27, 2022. Some of the required information includes:
- Most frequently dispensed drugs
- Most expensive medication
- Drugs that have registered the highest increase in cost.
Detailed reporting instructions are available from the Centers for Medicare and Medicaid Services, which is collecting the data.
HDHP Insulin Coverage
The Inflation Reduction Act of 2022 made changes to Section 223 of the IRS Code that affects High Deductible Health Plans (HDHPs). Specifically, an exception was added regarding insulin where beginning January 1, 2023, HDHPs will no longer need to meet the deductible before providing insulin coverage.
Contraceptive Coverage
On July 28, 2022, DOL, Treasury and HHS issued FAQs regarding implementing the Affordable Care Act. They included the contraceptive coverage mandate for non-grandfathered group health plans and insurers. The document confirms the mandate, clarifies rules on how coverage should be managed medically, and discusses enforcement strategies, among others.
The document also confirms that OTC contraception not covered by a health plan can be reimbursed from HSAs, health reimbursement arrangements, and health flexible spending accounts.
CARES Act and Relief Act Amendments Delayed
As of September 26, 2022, the deadline for implementing the amendments laid out by the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Taxpayer Certainty and Disaster Tax Relief (Relief) Act has been postponed until December 31, 2025.
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