Humana employer groups recently received a second email regarding data needed to comply with the Prescription Drug Data Collection (RxDC) reporting requirement. The email was sent from Horizon Insights. Humana revised its original data request issued mid-February in response to updated guidance issued by the Centers for Medicare and Medicaid Services (CMS). Plan sponsors who had coverage with Humana at any point in 2023, as well as those who already responded to the initial data request, will need to complete the updated survey by April 1.
The majority of the required RxDC data is maintained by the health insurance carrier, but not all. The survey will request information Humana does not collect:
- group health plan name (Ex: ABC Company Employee Benefit Plan)
- plan sponsor/employer name and contact information
- employer EIN
- plan sponsor principal place of business (level-funded / self-funded employers only)
- Form 5500 plan numbers (if applicable, generally 501)
- year(s) of Humana coverage (2023, 2024)
- average monthly premium (or premium equivalent) paid by members in 2023
- average monthly premium (or premium equivalent) paid by the employer in 2023
- member months and life years in 2023 (see pg. 32 of the RxDC Reporting Instructions)
- 2023 earned premium/premium equivalents (see Humana instructions)
CMS instructions clarify how the member-paid premium calculation is derived:
- premium paid by members for medical and pharmacy coverage,
- member payments for COBRA coverage, including the 2% administrative fee, and
- spousal and tobacco surcharges, if applicable.
CMS defines member-paid premium for self-funded groups differently than fully insured groups. Click here for the CMS self-funded calculation.
Plan sponsors should complete the survey link based on their Humana plan funding type:
- Click for Humana RxDC for fully-insured groups
- Click for Humana RxDC for self-funded groups (including level-funded groups)
Humana’s completion deadline is April 1. Failure to meet this deadline may require employers to submit information on their own or be subject to a CMS penalty of $100 per day per affected individual. The CMS deadline is June 1.
If you haven’t received the Humana email notification or need assistance, contact your Bukaty benefits consultant at 913.345.0440.
