Looking for answers about ACA Employer Reporting? This FAQ covers the most common questions about ACA compliance, Applicable Large Employer (ALE) requirements, Forms 1094-C and 1095-C, affordability calculations, Employer Mandate penalties, filing deadlines, and IRS reporting obligations.
Use the resources below to better understand ACA reporting requirements and how Lumelight helps employers simplify compliance and reduce reporting risk.
If we can assist with any specific needs or questions, please reach out to us.
ACA reporting refers to the annual reporting requirements established under the Affordable Care Act (ACA). Employers, insurers, and other coverage providers must report information about health coverage offered to employees and covered individuals using IRS Forms 1094 and 1095.
Applicable Large Employers (ALEs) use Forms 1094-C and 1095-C to report offers of coverage and demonstrate compliance with the ACA Employer Mandate.
Accurate ACA reporting helps employers avoid penalties and satisfy IRS requirements.
An Applicable Large Employer (ALE) is an employer that averaged at least 50 full-time employees, including full-time equivalent employees (FTEs), during the previous calendar year.
ALE status determines whether an employer is subject to:
ACA Employer Shared Responsibility (Employer Mandate) rules
IRS Forms 1094-C and 1095-C furnishing and filing obligations
Yes. Although the federal individual mandate penalty was reduced to $0, the ACA Employer Mandate remains fully in effect. Applicable Large Employers (ALEs) must continue offering affordable, minimum-value health coverage to eligible full-time employees and their dependents or risk employer shared responsibility penalties.
Employers subject to the mandate must also continue meeting ACA reporting requirements, including filing Forms 1094-C and 1095-C with the IRS each year.
For plan years beginning in 2026, employer-sponsored health coverage is considered affordable if the employee's required contribution for the lowest-cost self-only coverage option does not exceed 9.96% of the employee's household income.
Because employers generally do not know an employee's household income, the IRS allows employers to use one of three affordability safe harbors:
Federal Poverty Line (FPL) Safe Harbor
Rate of Pay Safe Harbor
Form W-2 Safe Harbor
Using one of these safe harbors helps employers determine affordability for ACA compliance and ACA employer reporting purposes.
ACA affordability is one of the key requirements of the ACA Employer Mandate.
If an Applicable Large Employer (ALE) offers coverage that is not affordable and a full-time employee receives a premium tax credit through a Health Insurance Marketplace, the employer may be subject to IRS penalties.
Monitoring affordability throughout the year helps employers reduce compliance risk and avoid unexpected assessments.
The IRS provides three ACA affordability safe harbor methods that employers can use to demonstrate affordability:
- Federal Poverty Line (FPL) Safe Harbor
Uses the federal poverty guidelines to establish a maximum employee contribution amount.- Rate of Pay Safe Harbor
Calculates affordability based on an employee's hourly rate or monthly salary.- Form W-2 Safe Harbor
Measures affordability using Box 1 wages reported on the employee's Form W-2.
Employers may use different safe harbors for different employee groups when applied consistently and in accordance with IRS rules.
ACA Employer Mandate penalties, also known as Employer Shared Responsibility Payments (ESRPs), may apply to Applicable Large Employers (ALEs) that:
Fail to offer minimum essential coverage to at least 95% of full-time employees and eligible dependents, or
Offer coverage that is unaffordable or does not provide minimum value.
The IRS adjusts ACA Employer Mandate penalty amounts annually.
For ACA purposes, a full-time employee is someone who works:
At least 30 hours per week, or
At least 130 hours per month
Employers use this definition when determining eligibility for health coverage and ACA reporting obligations.
A Full-Time Employee is an individual who averages at least 30 hours of service per week/130 hours per month.
A Full-Time Equivalent Employee (FTE) is a combination of employees who aren’t full-time, but who together are counted as full-time for purposes of determining their employer’s ALE status.
FTEs are not generally counted as full-time employees for the Employer Mandate’s offer of coverage requirements.
The ACA filing requirements depend on the employer's size and funding arrangement.
Applicable Large Employers (ALEs)
ALEs, regardless of their insurance type, must create:
Self-Insured Employers
Self-insured ALEs must comply with the requirements above and also generate Forms 1095-C for individuals who weren’t full-time, but who were enrolled in their self-insured coverage (COBRA participants, retirees, etc.)
Self-insured employers that are too small to qualify as an ALE must create:
Employers should ensure they are filing the correct ACA forms to remain compliant with IRS requirements.
Applicable Large Employers (ALEs) must distribute and file ACA reporting forms each year to comply with Affordable Care Act (ACA) requirements.
Employee Statement Deadline
Forms 1095-C must be furnished to employees by March 2 following the reporting year (or the next business day if March 2 falls on a weekend or holiday).
IRS Filing Deadlines
Employers must submit ACA reporting forms to the IRS by:
February 28 if filing on paper
March 31 if filing electronically
Because the IRS now requires nearly every employer to file electronically, the March 31 deadline applies to the vast majority of ACA filers. Employers can request an automatic 30-day extension to this deadline if need be.
Employers should monitor IRS guidance annually, as filing deadlines and reporting requirements may change. Lumelight helps employers stay on track with ACA reporting deadlines by automating data validation, form preparation, and electronic filing workflows.
Late, incomplete, or inaccurate ACA filings can result in significant IRS penalties.
Employers may be assessed penalties for:
Failing to file required ACA forms with the IRS
Failing to furnish employee statements on time
Filing forms with incorrect or incomplete information
Failing to file electronically when required
Lumelight's ACA Employer Reporting solution helps employers reduce compliance risk by identifying data issues early, streamlining ACA form preparation, and supporting accurate, on-time filing with the IRS.
Yes. Many employers choose to outsource ACA reporting to a specialized compliance and reporting partner to help:
Improve data accuracy
Reduce administrative burden
Meet IRS filing deadlines
Minimize compliance risk
Manage corrections and employee statements
Whether you are looking for ongoing ACA reporting services or support with a specific filing year, outsourcing ACA employer reporting can help improve accuracy, streamline compliance, and reduce reporting risk.
ACA reporting is a complex, data-intensive, and highly regulated compliance responsibility. Lumelight helps employers simplify this process by bringing together reporting expertise, filing support, and subject matter expertise. Our team of experts can help with tracking, unique company and plan designs, and general affordability issues to make reporting seamless.
With Lumelight, employers can streamline ACA reporting workflows, improve data quality, reduce compliance risk, and confidently meet annual IRS reporting requirements.
Below are the most common questions we receive about Dependent Verification. If we can assist with any specific needs or questions, please reach out to us.
A dependent eligibility verification audit is a process used by employers or plan sponsors to verify if the relationship between dependents and the employee or member aligns with the eligibility rules defined by the plan. For example, a valid birth certificate would confirm that a child is an eligible dependent of the member.
The dependent verification process ensures that only those who qualify as dependents – such as spouses, children, or others defined by the plan – receive benefits, thereby controlling costs and maintaining compliance with plan rules.
An ineligible dependent is someone who does not qualify for healthcare coverage based on the plan's eligibility rules. For example, an ex-spouse wouldn’t qualify as a dependent if the plan only covers a current legal spouse.
If an ineligible dependent is found enrolled in a benefit plan, the dependent should be removed. Then you should conduct a comprehensive dependent eligibility verification audit of all enrolled members. This will ensure no additional ineligible dependents remain on the plan, helping to lower plan costs, fulfill ERISA requirements, and reduce the risk of tax consequences and stop-loss claim denials.
To help ensure that no ineligible dependents are enrolled in a benefit plan, a comprehensive dependent verification review of each dependent’s eligibility should be conducted. This process should then be performed on an ongoing basis for newly added dependents throughout the year and during open enrollment. This provides peace of mind knowing that only eligible dependents are enrolled.
There’s no bad time to conduct a dependent eligibility audit with Lumelight. We will partner with you to find the timing that works best for your organization.
For optimal member experience, a dependent eligibility audit typically takes 12-16 weeks from kick-off to completion. This provides members with enough time to gather documents that they may not have readily available.
For the plan sponsor and/or the broker consultant, the time commitment averages less than an hour a week. This time is spent on setup, progress updates, and a wrap-up discussion with Lumelight experts for a presentation of the audit findings and guidance on the next steps.
Contact us and we can provide a detailed plan based on your needs.
It is best to verify the eligibility of all dependents as close as possible to the date they are added to the plan. We recommend starting with a comprehensive verification of all enrolled dependents to confirm current enrollment is accurate, followed by ongoing verification to verify any dependents added through new hires, qualifying life events, annual enrollment, or mergers and acquisitions.
Comprehensive verification should be considered every 2-3 years to look for relationship or eligibility changes that could lead to an ineligible dependent.
Spousal-only verifications should be conducted annually to verify that the relationship is still active and the surcharge or carve-out associated with the working spouse rule is applied correctly, if applicable.
Pricing for dependent verification depends on a few key factors—like the verification approach and number of households. For an accurate estimate, the best next step is to request a custom quote from the Lumelight team.
Dependent eligibility verification is important because:
Rising costs. Healthcare benefits are the second largest line item for most organizations and costs continue to increase. Both self-insured and fully insured plans benefit from dependent verification, which helps to mitigate expenses by removing ineligible dependents.
Compliance. Completion of a dependent eligibility audit helps reduce regulatory compliance risk under Sarbanes-Oxley, ERISA, and Department of Labor (DOL) guidelines by ensuring only eligible dependents are enrolled in benefit plans. This process strengthens internal controls, supports accurate reporting, and demonstrates compliance and due diligence in plan administration. Failure to prioritize this effort could result in financial penalties, tax consequences, claims denials, and increased exposure to legal and regulatory scrutiny.
Suspected or known issues. Sometimes, an ineligible dependent is discovered through the normal course of business. A comprehensive dependent verification audit is the best way to ensure that no additional ineligible dependents are currently covered by the plan. What are the average results of a dependent eligibility verification audit?
On average, dependent eligibility verification audits find that 9.5%* of enrolled dependents are found to be ineligible for benefits coverage. Results vary based on industry, plan eligibility criteria, and prior verification efforts.
See sample audit findings here.
*Results from audits conducted by Lumelight (formerly BMI Audit Services) from January 2022 - December 2024.
On average, a dependent eligibility verification audit provides an impressive ROI of 2,573%*. With the average annual plan sponsor cost of $7,000 per dependent, the savings identified through an audit often vastly outweigh the cost of conducting one.
Use Lumelight’s calculator to see how much you may be spending on ineligible dependents.
*Results from dependent audits conducted by Lumelight (formerly BMI Audit Services) from January 2022 - December 2024
Yes, dependent verification helps to reduce or prevent healthcare cost increases for plan sponsors, insurers, and members. Here’s how:
Removal of ineligible dependents reduces claims and other administrative costs year over year
Minimizes risk of mistakes & fraud by increasing member education and accountability to prevent enrollment of ineligible dependents
Improves integrity and compliance with regulations to avoid risks of fees and penalties
Prevents ineligible dependents from increasing costs for all members
Organizations that benefit from a comprehensive dependent verification include healthcare plans that:
have never conducted a dependent eligibility audit
have not completed an audit within the last 2-3 years
utilize a spousal surcharge or carve-out
experience high turnover or company mergers & acquisitions
have made changes to their coverage or eligibility rules
Organizations that benefit from ongoing dependent verification include healthcare plans that:
do not have a plan to manage ongoing verification internally
have recently completed a comprehensive audit
experience high turnover or company mergers & acquisitions
Yes. Lumelight’s dependent eligibility verification audits help plan fiduciaries comply with ERISA’s fiduciary duties by supporting their obligations to follow the terms of the plan and act in the sole interest of plan participants. These audits also help employers comply with ERISA’s exclusive benefit rule by ensuring that only truly eligible participants are benefiting from plan assets.
The 4-step dependent eligibility audit process is fast, simple, and easy for members to complete.
Communication
Clear instructions are sent via email and mail to plan members on how to complete the verification process for each dependent they have enrolled.
Document submission
Members submit required documents through a secure web portal, fax, or mail.
Review and verification
Lumelight reviews documents to verify the dependent relationship and notifies members if any additional information is needed.
Results
Lumelight shares the verification results with the members and plan sponsor throughout the process.
Dependent eligibility verification typically requires standard documents that confirm a dependent’s relationship to the plan participant. Lumelight can support all relationship types permitted under a plan.
Examples of a few common relationships with documents that could be requested are:
Spouses: Marriage certificate, tax return showing joint filing, or other proof of ongoing relationship
Children: Birth certificate, adoption papers, court order, or proof of guardianship
Other: Legal documents proving custody or financial dependency
Many organizations turn to a third party for dependent eligibility verification because managing an audit internally is time-consuming and resource intensive. Partnering with Lumelight helps streamline the process, maintain objectivity, and reduce potential friction by creating a clear separation between HR teams and plan members.
With Lumelight’s process, the plan sponsor and/or the broker consultant typically spend less than an hour a week on the project. Lumelight has robust tools and services to manage the entire eligibility verification process so that you don’t have to.
These include:
Experienced personnel dedicated to dependent eligibility verification
Personalized and effective member notifications
Fully managed distribution of communications
Online portal for member resources and document submissions
Member assistance via a live representative
Detailed review of submitted documents
Individual follow-up for members with incomplete documents
Online client portal with access to project status and member details
Wrap-up consultation with recommendations for next steps
It is important to consider various factors before hiring a third party for dependent eligibility verification. What matters most is selecting a third party that your organization trusts and is the best fit for your members.
We recommend also considering:
How long have they been in business?
Do they have the necessary privacy, security, and insurance policies?
Could other service offerings be considered a conflict of interest?
Do members have different methods for submitting the required information?
Is live help available for members who need assistance?
Is the verification process easy to follow and complete?
What is included in the price and what may cost extra?
If a dependent audit participant needs help, they can reach a live Lumelight representative via our helpline, available Monday–Thursday, 7:30 am-6:00 pm CT, and Friday, 7:30 am-4:00 pm CT. Participants can also submit a request for assistance at any time through our member portal.
Lumelight offers two types of dependent eligibility verification.
Comprehensive Dependent Verification
A comprehensive dependent eligibility verification is a thorough, documentation-based verification of all enrolled dependents within an organization's health plan(s). Results leave the organization with an accurate list of dependents who did and did not meet the specific eligibility requirements.Ongoing Dependent Verification
Ongoing dependent verification regularly checks the eligibility of dependents added through life events, new hires, open enrollment, and mergers & acquisitions. Conducted monthly, bi-monthly, or quarterly, this process helps prevent future coverage of ineligible dependents.
Additionally, comprehensive and ongoing verifications can include a Working Spouse or Affidavit-Only verification.
The dependent eligibility verification best practice in the industry is a combined approach that includes a comprehensive audit followed by ongoing verification. Lumelight can help you select the ideal approach for your needs and those of your members. Contact us for more information.
Yes, Lumelight has a standard process for verifying if a working spouse has other insurance options through their own employer. If they do, a spousal surcharge may be added to the member's premium, or the spouse may be excluded from the plan through a spousal carve-out policy.
Working spouse verification can be conducted as part of a comprehensive dependent eligibility audit, during ongoing verification, or on its own.
Yes, spousal-only verification can be conducted for spouses without including dependent children. Because divorces are often unreported, reviewing marital status annually keep records accurate.
Yes, Lumelight can accommodate an affidavit-only verification. An affidavit-only dependent verification relies on the member attesting that their dependents meet the plan’s eligibility requirements. This process does not require members to submit supporting documents like marriage certificates, birth certificates, or tax returns.
While an affidavit-only option is available, Lumelight strongly recommends collecting supporting documents as more substantial documentation of dependent eligibility and compliance with ERISA requirements.
The Mental Health Parity and Addiction Equity Act (MHPAEA) compliance remains a priority for employer-sponsored health plans. While enforcement of parts of the 2024 final rule is temporarily paused, the prior parity framework still applies, including the 2013 final rule, subsequent agency guidance, and the requirement to maintain an NQTL comparative analysis.
MHPAEA is a federal law that was passed in 2008 requiring group health plans offering mental health or substance use disorder benefits to provide those benefits in parity with medical and surgical benefits. This historic act continued the goal and evolution of the Mental Health Parity Act of 1996.
In practice, health plans must provide their mental health and substance use disorder benefits on substantially the same terms to be compliant meaning plans cannot apply more restrictive barriers to coverage or treatment limitations to mental health and substance use disorder benefits than their medical/surgical counterparts.
MHPAEA applies broadly to group health plans and was amended to include individual health insurance coverage following the Affordable Care Act (ACA). MHPAEA does not apply directly to small group health plans but does indirectly have requirements related to Essential Health Benefits as part of the ACA amendments. Non-federal government plans had a longstanding exception for MHPAEA compliance that was sunset in the Consolidated Appropriations Act 2023, and these plans are now required to follow the same guidance.
No. MHPAEA does not require a health plan to offer mental health or substance use disorder benefits. But if a plan does offer those benefits, they must comply with parity and testing requirements.
There are two distinct types of limitations discussed when considering if a plan is in parity:
Quantitative treatment limitations (QTLs) are the number-based limitations such as visit limits or cost-sharing requirements.
Non-quantitative treatment limitations (NQTLs) are focused on how plans administer benefits in practice such as limitations related to prior authorization, provider network adequacy, and medical necessity standards.
The Consolidated Appropriations Act (CAA21) built on the parity requirements of MHPAEA and created testing requirements related to non-quantitative treatment limitations (NQTLs). Prior to this additional testing requirement, plans only had testing parameters for QTLs, which largely missed the scope related to the MHPAEA requirements.
An NQTL comparative analysis is the written documentation a plan sponsor must maintain to show that NQTLs applicable to mental health and substance use disorder benefits comply with parity requirements. The analysis should demonstrate parity not only as written, but also in operation. This will involve plan specific data for testing.
No. The NQTL comparative analysis does not need to be submitted annually. But it does need to be current, kept on file, and ready to provide if requested by a federal or state agency or by plan participants under applicable timelines.
If requested by a federal or state agency, the NQTL comparative analysis must be provided within 10 days. If requested by an ERISA plan participant, it must be provided within 30 days.
No. In May 2025, the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury announced a temporary non-enforcement period for the 2024 MHPAEA final rule while the rule is reconsidered as part of an ongoing lawsuit related to ONLY the 2024 Final Rules. That non-enforcement period lasts until a final court decision is issued and for 18 months afterward.
Yes. The pre-2024 MHPAEA framework remains in effect, including the 2013 final rule, related guidance and FAQs, and the written comparative analysis requirement for NQTLs added by the Consolidated Appropriations Act of 2021. The temporary non-enforcement period does not eliminate MHPAEA compliance, nor the testing obligations set in CAA21.
During the non-enforcement period, employers do not have to comply with the new fiduciary certification requirement, certain new definitions, the meaningful benefits requirement, or the requirement to collect relevant data which would have more specifically defined the timing of plan specific data. Nothing in the 2024 Final Rule affected the requirements for parity, testing of NQTLs and QTLs, or definitions established through regulation or department guidance prior to 2024.
If a plan is found to be non-compliant with MHPAEA, the employer may need to take corrective action, such as reprocessing claims or refunding participants where applicable. Non-compliant plans may also face penalties of up to $100 per day per affected individual, and separate ERISA penalties may apply if required disclosures or analyses are not provided on time. Penalties from regulatory audits may be accumulated in addition to monetary penalties established in a private right of action by a plan participant in court.
Employers should continue reviewing plan design and administration for parity compliance, work with carriers, TPAs, PBMs, and other service providers, and keep NQTL & QTL comparative analyses current and defensible. The pause is not a reason to step back from compliance readiness.
A healthcare claims audit is an independent review of medical claims and/or pharmacy claims to verify that claims are processed accurately, paid according to plan terms, and administered in compliance with contractual and regulatory requirements.
Healthcare claims audits evaluate areas such as eligibility, plan design, industry billing standards, payment accuracy, fraud, waste and abuse indicators, and contractual compliance. The goal is to identify errors, improve vendor accountability, protect plan assets, and support fiduciary oversight.
For self-funded employers, medical and pharmacy claims audits provide valuable insight into how TPAs and PBMs are administering the plan and whether participants are receiving benefits as intended.
The only way to be sure that your healthcare plan’s claims are being processed correctly is to perform an audit. A healthcare claims audit will identify errors, confirm the plan is being administered as intended, and demonstrate compliance with federal regulations like ERISA, Sarbanes Oxley, and the Department of Labor (DOL) rules.
A healthcare claims audit can identify a variety of error types that occur during the claims process. These errors can lead to overpayments, underpayments, or noncompliance with regulations. Below are some of the common types of errors found during a medical claims audit:
Plan Design Errors
Plan design errors are mistakes or inconsistencies between claims processing and how the health plan is structured or documented. These include:
Incorrect copayment or deductible setups
Excluded services, such as cosmetic procedures or over-the-counter items
Misapplied benefit limits or exclusions, such as exceeding therapy visit limits
Payment for services that required prior approval from the insurer but were not authorized
Standard Industry Practice Violations
Standard industry practice violations refer to instances where claims are processed in ways that don't align with widely accepted healthcare or insurance industry norms. These include:
Use of invalid codes or inappropriate modifiers
Medically unlikely edits (units exceeding standard medical usage)
Incorrect application of bilateral or global payment rules
Unwarranted assistant or co-surgeon billing
Unbundling of procedures that should be billed as a single service.
Fraud, Waste, & Abuse Indicators
Claims that have Fraud, Waste, & Abuse indicators are those that could be misrepresenting a service, gaining financial benefit, or expending resources carelessly. These include:
Duplicate claims
Billing for services without proper destination, such as ambulance errors
Eligibility Errors
Eligibility errors are found in claims when the plan’s eligibility criteria are not met, but the claim is still paid by the plan. These include:
Dependents over the age of 26
Claims paid after the member’s termination date
Cost Control & Payment Errors
Cost control and payment errors are mistakes that result in overpayments, underpayments, or missed opportunities to reduce costs. These include:
Lack of medical necessity documentation
Overpayments due to pricing errors or missing provider discounts
Underpayments due to pricing errors or missing provider discounts
Other Party Liability Errors
Other party liability (OPL) errors are identified in claims that could potentially have another party that is responsible for the claim payment. Our auditors make selections and review claim-related documentation (eligibility dates, coordination of benefit documentation, accident details, etc.) to determine if another party is responsible for claim payment.
Review of high-cost claimants for stop-loss coverage
Failing to comply with the coordination of benefits (COB) when multiple insurers are involved - primary vs. secondary payer mistakes
Unaccounted third-party liability (e.g., workers’ compensation)
These errors can result from human oversight, system issues, lack of training, or weak investigative efforts. To see real-world examples of audit findings, visit our blog.
If you find an incorrectly paid healthcare claim within your plan, a medical audit of all claims should be conducted by a third-party auditor to confirm there are no more errors. Any errors that are uncovered should be presented to the third-party administrator or pharmacy benefit manager to ensure the system and processes are corrected and claims are adjusted as applicable.
Now is the best time to conduct a healthcare claims audit!
Lumelight advises beginning with an audit of the most recent 18 months of paid claims, followed by annual audits covering 12 months. It is best to align the audit period with the benefit plan for a complete review of items like deductibles and out-of-pocket calculations. Medical claims auditing reviews help organizations identify issues before they become costly systemic problems.
It is also important to conduct Implementation Audits when switching administrators, implementing plan design changes, or moving to a self-funded plan for the first time. This helps to ensure that the plan is set up correctly from the beginning and avoids incorrect payments due to implementation errors.
Healthcare claims should be audited at least annually. For organizations conducting their first audit, Lumelight recommends reviewing the most recent 18 months of paid claims to establish a baseline and identify any recurring issues.
Additional audits should be considered when:
Changing TPAs or PBMs
Implementing significant design changes
Transitioning to a self-funded health plan
Experiencing mergers, acquisitions, or workforce changes
Discovering a claim processing error or compliance concern
Regular medical claims auditing helps plan sponsors fulfill their fiduciary responsibilities, monitor vendor performance, and ensure plan assets are being used appropriately.
A healthcare claims audit typically spans 5–7 months from start to finish. The timeline is influenced by factors such as the availability of third-party administrators and pharmacy benefit managers. For plan sponsors or broker consultants, the process requires minimal effort, approximately 1-3 hours total, to submit plan documents, review email updates from Lumelight, and join kick-off and wrap-up sessions.
The cost of a healthcare claims audit is dependent on various factors like the number of plans and enrolled members, as well as the type of audit.
Request a quote so that we can provide you with a cost that aligns with your plan needs.
Healthcare claims audits provide independent verification that healthcare claims are being processed accurately, plan assets are being managed responsibly, and vendors are administering benefits according to plan documents and contractual obligations.
Organizations conduct healthcare claims audits for four primary reasons:
Compliance. Increased scrutiny by the Department of Labor (DOL) relative to proper discharge and monitoring of ERISA fiduciary duties by employers and/or sponsors of group health plans is reason enough to conduct an audit. Plan sponsors put a lot of effort into designing health care benefits for their employees and want to be assured that these benefits are being provided at the right cost. Based on data gathered from BMI customers in 2024, compliance was the top motivator for conducting an audit.
Fiduciary oversight. Many plan sponsors have never conducted an audit, yet draft authority on their bank account is granted to the third-party administrator for payment of the organization’s health care claims. Audits provide assurance that benefits are being provided as intended and claims are being paid accurately.
Rising costs. The cost of health care benefits is among the largest expense items for an employer and along with comprehensive healthcare reform, self-insured employers are facing additional pressures to ease the financial strain.
Suspected or known issues. Sometimes, an incorrectly processed claim is discovered through the normal course of business. The most effective way to ensure that no additional errors are going undetected is by conducting a thorough medical or pharmacy claims audit.
Ultimately, medical claims audits help employers protect their healthcare investment while ensuring employees receive benefits as intended.
Medical claims audits and pharmacy claims audits frequently uncover opportunities to improve plan performance, strengthen compliance, and reduce unnecessary spending. While results vary by organization, Lumelight commonly identifies claims processing errors representing approximately 0.5% to 3% of annual claims spend. Findings may lead to:
Recovery of incorrectly paid claims
Improved claims administration processes
Enhanced TPA or PBM accountability
Better compliance oversight
Reduced future payment errors
Increased confidence in vendor performance
Beyond financial recoveries, many employers value the peace of mind that comes from knowing their health plan is operating as intended and their fiduciary responsibilities are being fulfilled. Some TPAs will even help fund the cost of a follow-up audit.
See actual audit results here.
Healthcare claims audits improve compliance by verifying that claims are processed according to plan documents, administrative agreements, and applicable regulations. They help identify errors, operational weaknesses, and inconsistencies that could expose plan sponsors to financial or regulatory risk.
For self-funded health plans, audits provide documented evidence that fiduciaries are actively monitoring vendors and protecting plan assets. This oversight supports compliance with ERISA fiduciary obligations and demonstrates prudent plan management.
A healthcare claims audit can also identify:
Plan administration errors
Eligibility processing issues
Improper benefit application
Contract compliance concerns
Coordination of benefits errors
Pharmacy benefit management discrepancies
By proactively identifying issues, employers can address problems before they become larger compliance or financial risks.
Several regulations and contractual obligations influence medical claims auditing, particularly for self-funded employer-sponsored health plans.
These may include:
Employee Retirement Income Security Act (ERISA)
Department of Labor (DOL) fiduciary oversight requirements
Sarbanes-Oxley internal control expectations
Consolidated Appropriations Act (CAA)
Mental Health Parity and Addiction Equity Act (MHPAEA)
HIPAA privacy and security requirements
Administrative Services Only (ASO) agreements
Pharmacy Benefit Manager (PBM) contracts
A healthcare claims audit helps verify that claims administration aligns with these requirements while supporting prudent oversight of healthcare spending and vendor performance.
By identifying claims processing errors, medical claims audits and pharmacy claims audits help prevent future waste and ensure vendors follow contract terms, ultimately reducing overpayments and protecting plan funds.
Self-funded healthcare plans of all sizes benefit from claims audits benefit from medical claims audits and pharmacy claims audits, especially those with recent TPA transitions or high claims volume.
Organizations that have not audited their plan in the past two years, experienced mergers or eligibility changes, or want to validate vendor performance and compliance are ideal candidates for a medical and pharmacy claims audit.
Under ERISA, fiduciaries are required to act prudently and solely in the interest of plan participants. A claims audit supports this duty by verifying that claims are paid accurately, according to plan terms and contractual agreements. Medical claims audits provide documented supervision, help identify systemic errors and show that plan assets are being managed responsibly.
By proactively identifying errors and evaluating administrator performance, audits demonstrate careful management of plan assets, which is critical for ERISA compliance and avoiding litigation
Lumelight offers the following types of audits:
Medical Claims Audit
A medical claims audit is a review of medical insurance claims data to check for errors and make sure claims are paid correctly by the third-party administrator (TPA). The audit examines key areas such as duplicate charges, eligibility, standard industry practices, potential other party liability, and compliance with plan design and contract terms.
Prescription Claims Audit
A prescription (Rx) claims audit is a review of pharmacy insurance claims data to check for errors and make sure claims are paid correctly by the pharmacy benefit manager (PBM). The audit examines key areas such as dispensing fees, copayments, deductibles, out-of-pocket maximums, plan design compliance (including days’ supply limits, specialty drug rules, and exclusions), and plan utilization management (including prior authorization, quantity limits, and step therapy).
Additionally, a prescription drug claims audit can also include a Prescription Drug Manufacturer Rebate Audit and/or a Contractual Financial Guarantee Audit.
Focused Sampling
With focused sampling, 100% of paid claims are systematically reviewed against the client’s specific plan design using Lumelight’s proprietary category-based algorithms, which flags claims with potential errors. Flagged claims are then reviewed by experienced auditors who use their expertise to make final sample selections. This methodology may also be referred to as a comprehensive, judgmental, targeted or a 100% review audit.
Random Sampling
Random sampling begins with stratifying claims by the paid amount, such as $0 - $500, or $100,000+. A predetermined number of samples will be randomly selected from each stratum. These random samples are reviewed by experienced auditors who will determine if any of these claims have errors.
Here is an example of how Lumelight would stratify and select 200 random samples from 111,282 claims totaling $42,310,675 in paid claims:

Hybrid Sampling
Samples are chosen using a combination of focused and random sampling methodologies. This is best for plans that want a thorough review, as well as a measurement of performance guarantees.
Due to its effectiveness, Lumelight recommends conducting a focused audit. This is because the focused methodology programmatically reviews 100% of claims, with samples being selected by an expert auditor from those identified by the software as having potential errors. Using the focused sampling methodology is best for plans that want the most thorough review.
However, the decision is largely influenced by the plan sponsor’s desired outcome and the intended use of the results. Oftentimes, the Administrative Services Only Agreement (ASO) between the plan sponsor and third-party administrator dictates which approach may or may not be permitted.
A prescription drug manufacturer rebate audit is a review of each manufacturer’s rebate program to confirm that the correct pharmacy rebate amounts are being passed through and delivered back to the plan sponsor per the contracts. These audits help ensure that plan sponsors are receiving their full share of rebate dollars.
A financial guarantee audit evaluates whether a PBM is meeting the financial and/or performance guarantees outlined in the Administrative Services Only (ASO) contract, helping plan sponsors fulfill their fiduciary responsibilities.
This audit includes:
Complete contract analysis with consultative and cost containment recommendations.
Thorough evaluation of compliance with all contractual financial guarantees, such as average wholesale price (AWP) discounts, dispensing fees, minimum rebates, generic dispensing rates, and other applicable guarantees.
Lumelight’s medical and pharmacy claims audits follow a structured, multi-step process to deliver accurate results and actionable insights:
Kickoff & Planning
We begin with a kickoff call to align on audit goals, timelines, and responsibilities. The client shares plan documentation and sends the audit notification to the TPA and/or PBM.
Data Analysis & Sampling
Lumelight analyzes data provided by the TPA/PBM and makes sample selections based on the chosen sampling methodology.
Audit Review & Validation
The Lumelight team of auditors works together with the plan administrator to review a sample of claims. Claims are tested against various categories within the groupings of Plan Design, Standard Industry Practices, Eligibility, Cost Control Programs, Other Party Liability, and Fraud, Waste, & Abuse.
Reporting & Recommendations
Findings are shared through a detailed audit report, confirming correct and incorrect claims, accuracy ratings, and cost recovery opportunities. A wrap-up session follows to discuss the findings and recommend next steps.
Typical audit timeline: 5–7 months, depending on administrator availability and data readiness.
To start a claims audit, Lumelight will need the Summary Plan Descriptions (SPDs), plan amendments, stop-loss contracts, and the ASO agreement from the plan sponsor. The TPA/PBM will provide claims data and eligibility files.
It is important for organizations to do their homework before engaging with any audit firm. A few key considerations or questions to ask:
How long have they been in business?
How many audits have they successfully completed?
What third-party administrators have they worked with?
What type of audit technology or software is utilized?
Does the firm specialize in healthcare claims auditing?
Do they offer an audit approach that meets the organization’s objectives?
Do they offer additional services or products that could be considered a conflict of interest?
Yes. Most healthcare claims audits can be conducted remotely with minimal disruption to the plan sponsor.
Lumelight works directly with TPAs and PBMs to obtain claims data, eligibility files, and supporting documentation electronically. Audit reviews, status updates, and final reporting are typically completed through secure virtual meetings and digital file exchanges.
For most organizations, participation is limited to:
Providing plan documents
Attending a kickoff meeting
Reviewing periodic updates
Participating in the final findings presentation
This streamlined process allows employers and consultants to gain valuable audit insights without significant administrative burden.
Yes. Lumelight utilizes its own proprietary healthcare claims auditing software. AUDiT iQ™ is a healthcare claims auditing software designed to analyze 100% of claims data and efficiently identify inaccurate payments for sample selection during focused claims audits.
After the audit is completed, Lumelight delivers a comprehensive report detailing findings, observations, error rates, and opportunities for improvement.
The engagement concludes with a findings review session where our team walks through:
Claims reviewed
Errors identified
Financial impact
Compliance observations
Vendor performance insights
Recommended corrective actions
Where applicable, Lumelight assists clients in discussing findings with TPAs or PBMs and identifying opportunities to strengthen processes, recover funds, and prevent future errors.
The result is a clear roadmap for improving plan performance and protecting healthcare spend moving forward.
Below are the most common questions we receive about healthcare claims implementation audits.
A healthcare claims implementation audit, also called a plan setup audit, implementation review, pre-implementation audit, or post-implementation audit, is an independent review of how a third-party administrator (TPA) or pharmacy benefit manager (PBM) has configured your medical or pharmacy benefit plan.
Lumelight uses customized testing scenarios to confirm that claims processing systems are set up correctly to administer benefits according to your plan documents, Summary Plan Description (SPD), and intended plan design.
Implementation audits are commonly performed before a plan goes live, but they can also be completed after a plan goes live to identify setup issues early in the plan year.
By uncovering configuration errors before they impact members and plan spend, implementation audits help organizations:
Ensure positive member experience
Improve claims payment accuracy
Reduce administrative and financial risk
Protect plan assets
Support compliance and fiduciary responsibilities
Build confidence in TPA and PBM performance
A healthcare implementation audit is one of the most proactive ways to ensure your health plan starts—and stays—aligned with your intended benefits strategy.
Any employer, health plan sponsor, or consultant managing changes to a healthcare plan should perform an implementation audit.
Implementation audits are especially valuable when organizations are:
Changing TPAs or PBMs
Updating benefit structures or plan designs
Transitioning to a self-funded or self-insured model
Introducing new pharmacy or medical benefits
Consolidating plans after mergers or acquisitions
Even small configuration mistakes can lead to claim inaccuracies, member frustration, and unnecessary plan costs.
An independent healthcare claims implementation audit helps validate that systems are configured correctly before or shortly after claims processing begins.
HELPFUL TIP: Many TPAs and PBMs offer implementation credits that may help offset the cost of an audit. Ask about available credits during contract negotiations.
A healthcare claims implementation audit helps a self-funded health plan identify operational, financial, and regulatory risks before they become compliance violations. Because self-funded employers retain responsibility for the plan's compliance, even when they outsource administration to a TPA, an audit serves as an independent review of whether claims are being processed correctly and in accordance with applicable laws and plan documents.
How they support compliance:
Verifies alignment with plan documents
Helps meet ERISA requirements
Identifies potential financial and fiduciary risks
Prepares for regulatory examinations
A healthcare claims implementation audit prepares a self-funded health plan for compliance by confirming that plan provisions and claims processing systems are operating as intended and in accordance with regulations such as ERISA.
Beyond identifying errors, implementation audits demonstrate active fiduciary oversight and help create a documented compliance framework that can withstand regulatory scrutiny.
Lumelight offers implementation audits for medical and pharmacy benefit plans. Our team evaluates the plan setup against your intended benefit design and supporting plan documentation.
A healthcare plan implementation audit evaluates whether the claims processing system is set up to accurately administer the health plan according to plan documents.
Key areas of testing commonly include:
Accumulators
Benefit periods
Coinsurance
Copays
Deductibles
Exclusions
Inpatient and outpatient services
Limitations
Out-of-pocket maximums
Preventive care benefits
Professional services
If a claim produces an unexpected result during testing, it indicates a setup issue that would have also occurred in the live environment. By identifying these issues early, plan sponsors can improve the member experience, reduce payment errors, and strengthen compliance efforts.
Read about real-life implementation audit outcomes here.
The best time to conduct an implementation claims audit is as close to the effective date as possible. There are two different timing options to choose from:
Pre-Implementation
A pre-implementation audit is typically performed 3-4 months before the effective date so corrections can be made before live claims are processed.Post-Implementation
A post-implementation audit takes place after the plan has gone live, and live claims have started processing.
Both audit types are designed to identify setup errors early, helping organizations correct issues before they become widespread or costly.
Yes. Lumelight performs post-implementation audits for plans that are already active.
A post-implementation audit helps identify configuration errors, process inconsistencies, and claims administration issues early in the plan year—before they lead to larger financial or operational concerns.
A healthcare plan implementation audit takes an average of 3-4 months from kickoff through final reporting. For plan sponsors and consultants, the process is designed to require minimal administrative involvement, typically only 1-2 hours of total client time.
Healthcare implementation audit costs depend on several factors, including:
The number of plans being tested
Whether medical, pharmacy, or both plan types are included
The complexity of the benefit structure
The scope of testing required
The best way to determine the cost of healthcare implementation testing is to request a quote from the Lumelight team.
Do not forget to ask for implementation credits! Oftentimes, the new TPA or PBM will be willing to include implementation credits in the agreement to help cover the cost of the audit.
Healthcare plan implementation audits are important because even well-intentioned plan setups can contain errors.
Standard TPA or PBM system logic may unintentionally override custom plan provisions if configurations are not independently tested.
Lumelight takes an objective, member-focused approach to implementation auditing by using customized test scenarios to verify that claims are processed according to the intended plan design.
Conducting an implementation audit helps organizations:
Detect setup errors before they affect members
Reduce financial leakage and wasteful spending
Improve claims processing accuracy
Strengthen relationships with TPAs and PBMs
Increase confidence in plan administration
A proactive implementation audit creates a stronger foundation for long-term healthcare plan performance.
Healthcare implementation audits help plan sponsors achieve greater confidence in claims administration accuracy from day one.
When benefits are aligned with plan documents and processed correctly, organizations can:
Enhance member satisfaction by reducing billing and coverage issues
Strengthen fiduciary oversight through proactive error detection and correction
Prevent avoidable claims errors and plan overpayments
Reduce administrative rework and appeals
Improve operational accountability with TPAs and PBMs
Implementation audits help ensure that employees and members receive the benefits they were promised.
See examples of implementation audit outcomes here.
Implementation Audits help control healthcare costs by identifying setup errors early, before they result in ongoing financial waste and non-compliance with federal regulations.
Incorrect claims processing can lead to:
Overpayments
Underpayments
Compliance concerns
Member disruption
Increased administrative workload
By validating system configurations early, healthcare implementation audits help organizations reduce avoidable spending and improve plan performance.
Under ERISA, fiduciaries are expected to act prudently, in the best interest of plan participants, and according to the terms of the plan. A healthcare implementation audit supports fiduciary responsibilities by independently validating that claims systems are configured according to plan documents and contractual agreements.
Implementation audits also help organizations:
Demonstrate oversight of plan administration
Document proactive monitoring efforts
Identify systemic claims processing issues
Protect plan assets from unnecessary spending
An independent implementation audit provides documentation that plan sponsors are actively managing healthcare plan operations responsibly and prudently.
Pre-Implementation Audit
A pre-implementation audit begins approximately 3–4 months before the health plan effective date. This proactive review confirms that the administrator’s system configuration is accurately aligned with the intended plan design before live claims processing begins. It helps to:
Prevent claims processing errors before they affect members
Minimize disruptions during plan implementation and rollout
Safeguard plan assets by reducing avoidable claim inaccuracies
Reduce administrative rework and corrective actions after go-live
Increase confidence that benefits will be administered as designed from day one
Post-Implementation Audit
A post-implementation audit is conducted after the health plan is active and claims are already processing. This review identifies setup errors that may affect claims accuracy, member experience, or plan costs.
Lumelight recommends a pre-implementation audit whenever possible.
Validating plan configuration before going live helps organizations avoid:
Member frustration caused by incorrect claims processing
Time-consuming claim reprocessing efforts
Unnecessary financial exposure
Delays in issue resolution
Pre-implementation audits provide the greatest opportunity to correct issues before they affect employees, members, and plan performance.
Many TPAs and PBMs perform internal quality reviews as part of their implementation process. However, internal reviews may not fully evaluate plan configurations from the employer or member perspective. An independent healthcare implementation audit provides an objective assessment focused on:
Plan document alignment
Member impact
Claims accuracy
Fiduciary oversight
Financial protection
Independent testing helps uncover issues that may otherwise go undetected before claims are processed, while also ensuring that the plan documents are the source of truth, not the administrator’s internal processes.
Lumelight follows a structured healthcare implementation audit process designed to deliver clear findings and actionable recommendations.
Preliminary Steps
We begin with a kickoff call to align on audit goals, timeline, and responsibilities. The client shares plan documentation and sends the audit notification to the TPA and/or PBM.
Review of Documentation
Lumelight reviews plan documentation and administrator implementation materials which outline their processes, procedures, and system setup to determine which claims scenarios should be tested.
Claims Scenario Testing
Lumelight collaborates with the TPA and/or PBM to develop sample claim scenarios for testing. Claims are tested against various categories, including, but not limited to:
Accumulators
Benefit periods
Coinsurance
Copay levels and application
Deductibles
Exclusions
Inpatient and outpatient services
Limitations
Out-of-pocket calculations
Out-of-pocket maximums
Preventive care benefits
Professional services
Reporting & Recommendations
At the conclusion of the audit, Lumelight delivers a detailed report outlining:
Key findings
Configuration inconsistencies
Claims processing concerns
Recommended corrective actions
The Lumelight team also provides guidance for remediation and next steps.
The documents needed to start an implementation audit are:
Summary of Benefits and Coverage (SBC)
Current and prior Summary Plan Descriptions (SPDs)
Documentation outlining plan changes or modifications
Additional implementation materials, if applicable
These documents help ensure testing accurately reflects the intended plan design.
Lumelight conducts implementation audits using customized test claims designed to simulate real-world healthcare scenarios. These test claims allow our team to verify that:
System configurations are accurate
Benefits are processing correctly
Key administrative rules function as intended
Because testing is performed using controlled scenarios, live claims data is not required.
After completing a healthcare claims implementation audit, Lumelight delivers a detailed findings report and hosts a wrap-up session to review:
Audit results
Identified discrepancies
Recommended corrective actions
Next-step guidance
To help maintain long-term claims accuracy and plan performance, Lumelight also recommends conducting a comprehensive healthcare claims audit after the first full plan year.
For additional information about ongoing healthcare claims auditing services, contact the Lumelight team.
RxDC reporting is the annual Prescription Drug Data Collection requirement under Section 204 of the Consolidated Appropriations Act, 2021 (CAA) that requires group health plans and insurers to submit prescription drug and healthcare spending data to the Centers for Medicare & Medicaid Services (CMS) by June 1 each year. While carriers, TPAs, and PBMs often submit most data files on a plan’s behalf, plan sponsors remain legally responsible for complete and timely reporting which includes plan specific data on the P2 file and D1 file. CMS’s enforcement of the aggregation restriction now requires more granular, plan-level data coordination.
Below are the most common questions we receive about RxDC Reporting. If we can assist with any specific needs or questions, please reach out to us.
Prescription Drug Data Collection reporting, commonly known as RxDC reporting, is a federal transparency requirement included in the Consolidated Appropriations Act, 2021 (CAA). The law requires health insurance issuers in both the group and individual markets, as well as groups health plans to submit detailed annual data related to prescription drug costs and overall health care spending.
The reports include a file of overall plan information (P2), details about the plan’s enrollment information and allocation of premium dollars (D1), plus seven additional data files (D2-D8) that primarily reflect statistics about the plan’s prescription drug usage and medical claims data.
RxDC reporting is an annual reporting requirement established to give Congress and the related federal agencies further insight into spending broadly in the health plan sphere, so they could better implement guidance and potential further regulatory action. The broader transparency initiative resulted in annual data collection that informed prescription drug pricing trends AND broader total spending information related to health care premiums, enrollment, and spending by provider or clinical category.
The goal of RxDC reporting is to help the federal government better understand:
RxDC reporting generally applies to health insurance issuers and employer-sponsored group health plans, including both fully insured and self-funded health plans. Established under the Consolidated Appropriations Act (CAA), RxDC reporting is submitted annually to the Centers for Medicare & Medicaid Services (CMS) to improve transparency around prescription drug and healthcare spending.
Entities commonly involved in RxDC reporting include:
Although employers may delegate portions of the reporting to carriers, TPAs, or PBMs, the group health plan remains responsible for ensuring the required RxDC data is submitted accurately and on time.
health insurance issuers in group and individual markets
fully insured group health plans,
self-funded group health plans (this includes level-funded!),
non-federal government plans,
church plans, and
Federal Employees Health Benefits (FEHB) plans.
While reporting obligations remain the same, some plan vendors may offer to support all or some of a group health plans RxDC reporting. It is important for employers and advisors to coordinate early with carriers, PBMs, and TPAs to determine how each required piece will be submitted.
Certain types of coverage are typically exempt from RxDC (Prescription Drug Data Collection) reporting requirements, including:
These types of coverage are generally excluded because they do not meet the definition of a group health plan subject to the Centers for Medicare & Medicaid Services (CMS) RxDC reporting requirements under the Consolidated Appropriations Act (CAA).
Unlike other group health plan responsibilities, there is no exemption for grandfathered or grandmothered health plans.
RxDC reporting is due annually by June 1st. The data reported relates to the calendar year prior to the deadline. The “reference year” is the term for the calendar year of data your reporting is on.
RxDC reporting is completed on a calendar-year basis, regardless of whether a group health plan operates on a non-calendar plan year. As a result, employers with non-calendar year plans may need to gather data spanning portions of two separate plan years.
EXAMPLE: Reporting for the 2025 reference year must be submitted by June 1, 2026.
If your plan year is from June 1, 2025, to May 31, 2026, data will need to be collected from the plan year spanning January 1, 2025, through June and the plan year spanning June 1, 2025, through the end of the year.
RxDC reporting consists of multiple data files and a plan identifying file that relate broadly to:
Premium split data
Enrollment data
Prescription drug spending trends
Rebates
Cost-sharing
Medical spending by service categories
P1, P2 and P3 are the plan list files used in RxDC reporting to identify the health plans included in a Prescription Drug Data Collection (RxDC) submission.
The purpose of the P files is to provide basic identifying information about the plans associated with the RxDC submission before the detailed spending and prescription drug data files (D1–D8) are reported. This file acts as a “cover letter” and must be submitted any time another RxDC file is submitted. This means that if an employer’s D2-D8 files are submitted in different parts by numerous vendors, the employer’s P2 file must be included with each distinct submission.
The RxDC D1 through D8 files are the detailed data files required as part of the broader Prescription Drug Data Collection (RxDC) reporting requirements under the Consolidated Appropriations Act (CAA). These files provide federal agencies with information about health care spending, prescription drug costs, premiums, rebates, enrollment, and medical claims data that are evaluated and reported to Congress annually.
Each D file captures a different category of information related to a health plan’s medical and pharmacy spending.
D1 – Premium and Life-Years Data
D2 – Spending by Category
D3 – Top 50 Most Frequent Brand Drugs
D4 – Top 50 Most Costly Drugs
D5 – Top 50 Drugs by Spending Increase
D6 – Rx Totals
D7 – Rx Rebates by Therapeutic Class
D8 – Rx Rebates for the Top 25 Drugs
Because the reporting process is highly technical, employers often work with carriers, TPAs, ASOs, PBMs, and other vendors to prepare and submit the required D files accurately and on time.
The RxDC narrative response is the written explanation submitted as part of the annual reporting package. The narrative response helps CMS understand how the reporting entity compiled and submitted the RxDC data files.
The narrative response is required to be included in the RxDC submission and is commonly used to explain how certain calculations were made, coordination of reporting entities or uniquely designed plan entities such as Multiple Employer Welfare Arrangements (MEWAs). This document may include explanations such as:
A clear and complete narrative response helps provide context for the reported data and can assist CMS in understanding the methodology used to prepare the annual RxDC submission, particularly when multiple reporting vendors or unique plan structures are involved.
The reports must be submitted electronically through the RxDC module within CMS’s Health Insurance Oversight System (HIOS). It typically takes multiple weeks to create the account required to file with this system, and there are currently no alternative submission methods.
It is important to note for plans and advisors looking to complete this reporting requirement on behalf of plans that reporting entity access also involves designated employees within your organization, background checks, and significant security hurdles before files can even be uploaded.
The good faith compliance relief that was available for the 2020 and 2021 reports is no longer available.
The CAA did not specifically outline a RxDC reporting penalty for non-compliance and would default to the ERISA penalties for noncompliance of $100 per plan participant per day, were the plan to be under audit.
Additional potential risks of incomplete or missed RxDC reporting may include:
Incomplete submissions, inaccurate data, or missed deadlines may also create complications if CMS determines that required files or narrative responses were not properly submitted.
Not necessarily. Plan sponsors are ultimately responsible for ensuring that this reporting is completed on a timely basis. Plan sponsors should:
Due to the complex requirements within these P2 and D1 files, most employers will need assistance from a vendor or compliance expert to create these reports.
Employers with a carrier, TPA, and/or PBM that will assist with the P2 and D1 files should be mindful of any deadlines the vendor has established for their assistance and should plan for an alternative solution if they’re unable to meet those deadlines.
Yes. Group health plans can have plan vendors or outside third-party vendors submit all or a portion of their RxDC reporting.
While plan sponsors should obtain written confirmation that each reporting responsibility will be completed by the appropriate vendor, this is especially important for self-funded group health plans, where the plan sponsor retains ultimate responsibility for ensuring all required RxDC data files are submitted accurately and on time. Written documentation can also help demonstrate compliance if questions arise during an audit or regulatory review.
If multiple vendors are involved in the reporting process, employers should clearly define which organization is responsible for each required submission to help avoid reporting gaps, duplicate submissions, or missed deadlines.
Many vendors focus on the “heavy lift” that the D2-D8 files require, and don’t have the same convenient access to the information that the D1 and P2 files require as they do for the other data sets.
These files often require employer-specific information, such as enrollment, premium, and payroll-related data, that a carrier, TPA, or PBM must obtain from the group health plan before they can prepare or submit them.
As a result, many employers work with a compliance partner or another reporting vendor to prepare the D1 and P2 files while their carrier, TPA, or PBM completes the D2–D8 files.
Employers should respond timely to requests from carriers, TPAs, or PBMs for additional data required to complete submissions on their behalf. These deadlines are often around late March, early April so these reporting entities can complete their heavy lift but are often ahead of when plan sponsors and advisors think about this annual reporting requirement.
If plans miss these deadlines, it is good to have a back-up plan of a trusted compliance partner to help navigate the checklist for this compliance obligation.
Lumelight simplifies the RxDC reporting process by managing the preparation and submission of key reporting files on your organization’s behalf. We work directly with employers, brokers, TPAs, PBMs, and other vendors to ensure your RxDC reporting requirements are completed accurately, efficiently, and on time.
As part of our RxDC reporting support services, Lumelight will:
Our goal is to reduce the administrative burden of RxDC reporting while helping employers stay compliant with the annual Prescription Drug Data Collection requirements under Section 204 of the Consolidated Appropriations Act, 2021 (CAA).
If you are part of a larger insurer, TPA, or PBM organization we can help with that too! All you have to do is reach out and our experts are ready to help based on your needs.
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Why Lumelight
Lumelight is an integrated workplace administration and compliance company. We support brokers and TPAs who help employers navigate complex areas like benefits design, compliance, and administration.
We’re not here to maintain the status quo – we’re here to transform an industry. Whether you’re a regulatory specialist, data analyst or client advisor, your role drives confidence and mitigates risk for organizations nationwide.
We handle the complexities of benefits compliance and administration, empowering you to focus on what you do best.