Drug Cost Reporting Deadlines

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Its called Drug Cost Reporting so naturally the marketplace would think that the PBM (Pharmacy Benefit Manager)

For the TPAs in the Market Place that have had a chance to look at the Drug Cost Reporting requirements, you’ve probably also had the realization that pulling off this reporting is going to be a lot more difficult than you might have initially thought.

Its called Drug Cost Reporting so naturally the marketplace would think that the PBM (Pharmacy Benefit Manager) is going to be supplying most of this data. The thing to know is that the PBM is providing the majority of the needed data, but unfortunately what we are finding in the marketplace is that the PBMs are making logical decisions based upon their circumstances. What we mean is that, when one takes a look at the reporting requirements, they find that for the PBMs, in most cases it is in their best interest to just provide the data to the plan sponsor and allow the plan sponsor to report for themselves.

falling back onto the TPAs

DrugCostReporting
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As more responsibility is falling back onto the TPAs, we at DrugCostReporting.com are having conversations with them to help clarify how difficult it is to get their hands around all of the required administration.

As a holding company, we also own ACAReportingService.com. What we are seeing with the Drug Cost Reporting is very reminiscent of what we saw during the first year of ACA Reporting. Everyone in the industry was trying to figure out what this new compliance item was and how they would complete it. For this reason, we have launched consulting services as well as services provided all the way down to the plan sponsor. The goal of this is to help plan sponsors complete accurate and timely Drug Cost Reports.

Manufacturer Assistance Payments

Manufacturer Assistance Payments $ Needed FIRST in Drug Cost Reporting

Drug cost Reporting, Instructions

As the marketplace is scrambling to complete Drug and Healthcare Cost Reporting for the very first time, PBMs and TPAs are discovering that BEFORE they can complete their end of the reporting they FIRST must have the amounts received by the Plan for Manufacturers Assistance Program payments. 

This is just beginning to create quite a bottleneck and here is why.  Think of this like ‘Data Dominos’ . . .

  • The TPA must-have files D3-D8 complete by the PBM before they can complete their side of the reporting.  Therefore the TPA is ‘waiting’ on the PBM.
  • The PBM must have data regarding Manufacturers Assistance program payments before they can create their end of the reporting.  Therefore they are ‘waiting’ on these vendors to provide those amounts.

See the problem? 

And it gets worse because most of the organizations that offer services to help plan sponsors capture manufacturer's assistance payments are unaware that they are the bottleneck.  In fact, as we have questions the marketplace we have found that most (or all) of these vendors have not even started to look into what is required from them regarding this new reporting.