January 13, 2020

Beginning January 1, 2020, TPAs, PBMs, and in some cases, plan sponsors, will be required to report information on prescription drug coverage for Medicare beneficiaries to CMS. In preparation, the Centers for Medicare and Medicaid Services (CMS) issued an updated User Guide and FAQs. Plan sponsors who provide prescription drug coverage to Medicare beneficiaries should keep in mind the following:

• In most cases, group health plan TPAs or PBMs will be responsible for reporting. However, to fulfill this reporting requirement, TPAs or PBMs may need additional data feeds from group health plans.
• As with prior CMS reporting obligations, additional TPA or PBM fees may be associated with this reporting.

Next Steps

We recommend that employers:

• Verify which party will be responsible for reporting to CMS and
• Be prepared to discuss with TPAs and PBMs the types of information that will be reported to CMS to ensure accuracy.

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Articles & Guides Pharmacy/Prescription Drugs