Below is the original communication that was sent to a limited number of individuals that serve as a main contact for Employee Benefit Trusts with Medical Coverage. You will find the subsequent form that was sent out below this original communication.

CAA Section 204 Rx Reporting – Group Action Required

As part of the Consolidated Appropriations Act (CAA), employer-sponsored health plans must submit certain information about prescription drug and healthcare spending to the Departments of Health and Human Services (HHS), Labor (DOL), and Treasury (collectively, the "Departments"). The reports are expected to enhance transparency and shed light on how prescription drugs, particularly, contribute to the growth of healthcare spending and the cost of health coverage.

This data must be submitted annually through a web portal that has been set up by the Centers for Medicare & Medicaid Services (CMS). By law, the employer-sponsored health plan is responsible for this reporting requirement.

Christian Brothers Services is prepared to provide such data on your behalf. However, we need additional input from you to compile the most accurate and up-to-date information.

The first reports for calendar years 2020 and 2021 are due by Tuesday, December 27, 2022. Subsequent reports will be due annually on June 1, for the preceding year.

The required data that must be submitted under the cost reporting regulations is referred to by regulators as a "Section 204 data submission," a reference to where the requirement is found in the CAA. The Section 204 data submission requires plans and insurers to submit certain information on prescription drug and other healthcare spending annually. The submission process requires one plan information file (P2 for Christian Brothers Employee Benefit Trust clients), and eight data files (D1-D8).

The information includes:

Regulators expect most of the data collection to be conducted by insurers and third parties with that data aggregated at the state and market segment rather than on a plan-by-plan basis. This allows the government to conduct more meaningful data analysis if most of the information is already aggregated.

Christian Brothers Services is prepared to provide this valuable data collection service for our clients. Christian Brothers has worked with Express Scripts, Inc. (ESI) your Pharmacy Benefits Manager (PBM) to provide the necessary data in aggregate for all CBEBT clients for files D3-D8. Christian Brothers Services is able to provide the data necessary for D2.


We need to VERIFY the information that we have for the submission of P2 and we need to collect the Premium/Contribution split between you and the enrollees for D1. The average monthly contributions are optional for the calendar year 2020 and 2021 data being reported by Tuesday, December 27, 2022, however, CBS is requiring this information in order to be able to submit this data on your behalf. Accurate contribution data split between employer and employee are required as of June 1, 2023, and every year thereafter, requiring us to periodically update this information. We need to include employer size which is determined by the total number of employees you had on average for the reference year. These include full-time, part-time, and seasonal (any W2'd employee).

We will be sending a PDF document via AdobeSign to one main contact at each group to verify the basic employer information, tax identification number, contributions split, and employer size. We will need to receive this information back in our office no later than Wednesday, December 7. Please watch for this communication, and if you are not the correct person, please pass it along to the appropriate person as we are sending only one request per group.


Important notice for new CBEBT clients with an effective date after January 1, 2020: All clients with an effective date after January 1, 2020 must contact their prior carrier and/or PBM to coordinate the required data file submissions directly to the government, for the time periods prior to joining CBEBT.

Notice for terminated groups: information for D2-D8 will be sent in aggregate, but CBS will not be submitting P2 or D1 information on behalf of terminated groups.

Thank you in advance for your assistance in compiling this information.

Sample of the form sent to groups with medical coverage.
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