Learn more about Prescription Drug Reporting and Employee Benefit Plan Limit Increase:
PRESCRIPTION DRUG REPORTING DUE BY DECEMBER 27, 2022
A new transparency provision requires
employer-sponsored health plans and
health insurance issuers to annually report
information about prescription drugs and
health care spending to the federal
government. This reporting process is
referred to as the “prescription drug data
collection” (or “RxDC report”).
The first RxDC report is due by Dec. 27,
2022, and covers data for 2020 and 2021.
Going forward, the annual deadline for the
RxDC report is June 1. This means that the
second RxDC report is due by June 1, 2023,
covering data for 2022.
Impact on Employers
The RxDC reporting requirement applies to
employer-sponsored group health plans,
including fully insured and self-funded
plans. According to interim final rules,
employers may use issuers, third-party
administrators (TPAs), pharmacy benefit
managers (PBMs) or other third parties to
submit the RxDC reports on their behalf.
Federal agencies have stated that, although
employers can submit the RxDC reports on
their own, they expect it will be rare for
employers to do so.
Action Steps
Employers should reach out to their issuers,
TPAs or PBMs, as applicable, to confirm that
they will submit the RxDC reports for their
health plans. Employers should also update
their written agreements with these third
parties to reflect this reporting
responsibility.
In addition, employers with self-funded
plans should monitor their TPA’s or PBM’s
compliance with the RxDC reporting. Unlike
fully insured plans, the legal responsibility
for RxDC reporting stays with a self-insured
plan even if its TPA or PBM agrees to
provide the report on its behalf.
EMPLOYEE BENEFIT PLAN LIMITS INCREASE FOR 2023
Many employee benefits are subject to
annual dollar limits that are updated for
inflation before the beginning of each
calendar year. Due to high inflation rates,
many employee benefit plan limits will
substantially increase in 2023. Note that
some benefit limits are not indexed for
inflation, such as the dependent care FSA
limit and the catch-up contribution limit for
HSAs.
For plan years beginning on or after Jan. 1,
2023, the following limits have increased:
• HSA contribution limits:
o Single coverage—$3,850 (up $200
from 2022)
o Family coverage—$7,750 (up $450
from 2022)
• Health FSA contribution limit—$3,050
(up $200 from 2022)
• Health FSA carryover limit—$610 (up
$40 from 2022)
• Transportation fringe benefit plan
monthly limits—$300 (up $20 from
2022)
• Employees’ 401(k) elective deferral
limit—$22,500 (up $2,000 from 2022)
• Employees’ 401(k) catch-up contribution
limit—$7,500 (up $1,000 from 2022)
Provided to you by MFC Benefits, LLC
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