Can employer groups choose to submit their required data to CMS directly, rather than Blue Cross NC submitting it on their behalf?

Self-funded groups only may choose to submit their D1 reporting data via the HIOS platform but must have indicated this choice within the survey no later than March 31, 2026. If a self-funded group chose to submit D1 (and P2 as it is required from all submitters) and indicated as such within the survey by the deadline, Blue Cross NC did not submit D1 on the group’s behalf but submitted all other relevant data on the group’s behalf.