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Understanding CAA Reporting: What Self-Funded Employers Need to Know

  • Writer: C. B. Wood Financial
    C. B. Wood Financial
  • Apr 2
  • 2 min read


The Consolidated Appropriations Act (CAA) introduced significant reporting requirements for employer-sponsored health plans, including self-funded plans. It's crucial for self-funded employers to understand their obligations under this legislation to maintain compliance and avoid penalties.


What is CAA Reporting?

CAA reporting includes provisions that aim to improve transparency in healthcare pricing and spending. A key component is the Prescription Drug Data Collection (RxDC) report, which requires health plans to submit detailed information on prescription drug costs, premiums, and other healthcare expenses.


What Self-Funded Employers Need to Do

  1. Submit the RxDC Report: Self-funded employers must ensure their plan submits an annual report to the Centers for Medicare & Medicaid Services (CMS). While third-party administrators (TPAs) and pharmacy benefit managers (PBMs) often assist with this, the employer remains ultimately responsible.

  2. Ensure Compliance with Transparency Rules: Employers must confirm their plans adhere to cost transparency requirements, including disclosing broker and consultant compensation.

  3. Review and Validate Data: Even if a TPA or PBM handles reporting, employers should verify the accuracy of submitted data to mitigate compliance risks.


Key Deadlines and Consequences

CAA reporting deadlines typically fall at the end of June each year. Missing these deadlines or submitting incomplete data could result in penalties or compliance actions.


How to Prepare

  • Communicate with Vendors: Ensure TPAs, PBMs, and consultants understand reporting requirements and deadlines.

  • Audit Your Data: Regularly review healthcare and prescription drug costs to ensure accuracy.

  • Stay Informed: CAA requirements may evolve, so keeping up with regulatory updates is essential.


Self-funded employers who proactively manage their CAA reporting obligations will not only maintain compliance but also gain valuable insights into their healthcare spending, ultimately leading to better cost control and plan management.


If you need assistance navigating these requirements, working with an experienced benefits advisor can help streamline the process.




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