Does Blue Cross NC have all the data required for submission in its system?

No. Blue Cross NC does not process data required for section P2 and D1. Blue Cross NC reached out to groups individually with a survey to request the necessary information. Groups need to submit the data back to Blue Cross NC by March 31, 2026, for Blue Cross NC to fully complete the report. If groups fail to respond to the requests for data, it will impact the group’s compliance with the mandate and groups will be required to submit the information to CMS directly.

For P2, Blue Cross NC does not possess the Form 5500 Plan Number. The CMS instructions state, "If applicable, enter the 3-digit plan number reported on the IRS Form 5500 filed with the Department of Labor. If there is more than one value, separate them with a semicolon." Blue Cross NC requested Form 5500 numbers from those groups subject to ERISA and must file a 5500 number with the IRS and, therefore, would have data applicable to this P2 field. For reference, a group may find their Form 5500 plan number by visiting the US Department of Labor Form 5500 Search Tool.

For D1, Blue Cross NC must report premium and life-years. For self-funded plans and other arrangements that do not rely exclusively on premiums, Blue Cross NC must report the premium equivalent amounts. The stop-loss premium paid is an element of the required premium equivalent amounts calculation. Blue Cross NC has this information for those groups that have stop-loss coverage through Blue Cross NC, but for those that use other stop-loss carriers, we do not possess this information and have requested it when needed. Blue Cross NC also does not process the monthly premium paid by employers versus employees. Blue Cross NC must collect this data for the relevant reference year.