July 23, 2021
HHS, DOL, and Treasury issued a request for information (RFI) to gather input from the public regarding implementation considerations for the data collection required under section 204 Consolidated Appropriations Act, and the associated impact on group health plans and health insurance issuers. The RFI included many detailed questions, many of which are best answered by the PBMs or other stakeholders.
The Business Group and P4ESC focused our comments on the principles that we believe should shape the regulatory requirements and responsibilities:
- 1 | identifying ownership and control of the data;
- 2 | aligning the reporting responsibility with the ownership and control;
- 3 | limiting the cost burden to employers; and
- 4 | delaying the initial reporting until the requirements are issued and the parties have developed mechanisms for compliance.