If a plan uses a different carrier or vendor for pharmacy, behavioral health, wellness, and/or stop-loss, what does Blue Cross NC expect those entities to report on the group's behalf?
The information submitted in P2, specifically the group health plan name and group health plan number, will tie multiple submission to a single employer/group health plan and must be submitted by each entity submitting a report on behalf of an employer/group health plan. Clients will need to coordinate with other carriers/vendors based on carve-out arrangements to submit other relevant data. Clients need to confirm their other carriers/vendors are submitting the appropriate data in the context of the services they provide to your plan. Blue Cross NC expects that carve out vendors will submit the following data within the context of the services they provide as Blue Cross NC will not provide that data on the Plan's behalf:
- Carve out pharmacy carriers should submit P2 and D3-D8 data
- Carve out behavioral carrier that pays claims should submit P2 and D2
- Carve out wellness carrier that pays claims should submit P2 and D2
Please note, D2 data is aggregated at the vendor/carrier reporting entity level.
This information is intended to be informational only and is a guide based on the direction provided by CMS in the RxDC reporting instructions. Plans and their carriers should consult their own legal and compliance teams on compliance with this mandate.