Under the Consolidated Appropriations Act (CAA), health insurers offering group or individual health coverage and self-funded (ASO) group health plans are required to report data annually regarding prescription drugs and health care spending to the Departments of Health and Human Services, Labor, and Treasury (Tri-Agencies). This information must be submitted to CMS by June 1, 2025, for 2024 data, through a web portal set up by the Centers for Medicare & Medicaid Services (CMS).
The easiest way for groups to be compliant with this legislation is if they submit certain premium data to their carrier by a specific deadline prior to the CMS deadline or some carriers will collect the necessary data without the group needing to do anything. The carrier will then submit the data to CMS on their behalf.
Below is a summary by carrier (that we have received to date) with how they will be handling for 2025, deadlines, premium data format, instructions, survey links and links to supporting documentation.
| Carrier | Data Collection Summary | Carrier Links |
| Aetna |
For plan sponsors with integrated pharmacy benefits with Aetna, Aetna will submit all required reports on their behalf. For plan sponsors who contract directly with a PBM (including Caremark)
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N/A |
| Anthem NY | Fully Insured clients must complete the emailed survey, which includes EE/ER percentages by 3/19. ASO clients must complete the opt in survey by 3/19 if they want Anthem to file D1 on their behalf. The opt in survey was already emailed to ASO clients. | Survey Link |
| Anthem CT |
They will be sending out notifications starting 2/19 that will include a link to a survey which has to be completed & returned by 3/19/25. They will be filing the report for their fully Insured and Anthem Balanced Funding groups. |
Survey Link |
| Cigna | Cigna has been collecting, and will continue to collect, the required information for the June 1, 2024 (and future) submissions, through existing processes, such as case set-up and renewal. | N/A |
| Horizon | Horizon will be completing the process for all Fully Insured and Level Select groups without any data needed from the group or broker. ASO groups will need to file premium information (D1) directly to CMS. Horizon or the PBM will file Rx information (P2, D2, D3-D8) for ASO groups. |
N/A |
| UHC/Oxford | UHC will require customers to complete a Request for Information (RFI) by 3/31/25. The RFI Survey Worksheet to gather information needed is now available. The RFI is embedded in the UHC Employer & Broker Portals and can be accessed after the employer or their delegate signs in with their secure passcode. The RFI must be submitted on the portal by 3/31/25 |
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We will communicate additional information as it becomes available.