From Reporting to Benchmarking: Ensuring Complete CAA Compliance


With the recent passing of the June 1 deadline for reporting Consolidated Appropriations Act (CAA) required prescription drug data to government agencies, plan sponsors must ask themselves a crucial question:


Has my carrier, claims payer, TPA, or PBM timely submitted the required Rx data on my plan’s behalf, and does this mean I am fully compliant with this section of the CAA?


The answer likely falls between “maybe” and “no.”


In many cases, especially for level-funded, self-funded, and large fully insured plans, prescription drug data is available on an individual plan basis, rather than aggregated with other plans. Reporting this Rx data fulfills one core requirement of the CAA. However, the legislative intent and overarching goal of the CAA is for plan sponsors to access and utilize this plan data, captured through required transparency, for the benefit of plan participants and their beneficiaries.


Understanding the Four Pillars of the CAA


Compliance with the CAA necessitates that health plans meet each of its four pillars as a “means” to an “end”—creating a fiduciary process that ensures plan participants benefit from the data transparency. Therefore, simply satisfying the Rx data reporting function does not complete a plan sponsor’s duty. It is merely the beginning.


Steps to Fulfill Your Rx Reporting Duty

So, how can plan sponsors fully comply with the CAA’s prescription drug reporting requirements? Here’s a step-by-step approach:


  1. Receive and Use the Data: Plan sponsors must not only ensure that their carrier, claims payer, TPA, or PBM reports the data but also actively receive and utilize this information.
  2. Benchmark the Data: Use the reported data to benchmark against alternative solutions. This comparison can highlight areas where the plan can improve or where costs can be reduced for the benefit of plan participants.
  3. Create a Fiduciary Process: Data that is not analyzed and scrutinized is essentially useless. A thorough benchmarking process is key to establishing a fiduciary process, ensuring that decisions made are in the best interest of the plan participants.

Navigating Challenges

Creating a fiduciary process without access to the reported Rx data is like navigating blindfolded. If your carrier, claims payer, TPA, or PBM does not share individualized Rx plan data, it might be time to consider finding a new partner.


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If you need help accessing and analyzing your data to ensure compliance and optimize your health plan, contact us at

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