On Nov. 4, NH INS outlined PBM, insurer aggregate rebate reporting.
NH INS issued Bulletin #INS 24-067-AB, guidance on reporting pharmaceutical rebates
Guidance aligns with recent amendments to law, which mandate detailed disclosures from PBMs and insurers about rebates received from pharmaceutical manufacturers.
Follows enactment of NH SB 555, chaptered Ch 0305, to set aggregate rebate report requirements on non-Medicaid and non-Ryan White HIV-AIDS medications, #216756.
Reporting Requirements
For insurers, effective Mar. 1, 2025, send NH INS annual report on discounts, actuarial certification, methodology to calculate rebate, actual and calculated estimated rebates.
Insurers must use the NH INS designated Insurer Rx Rebate Attestation template.
PBMs to submit summary of rebates received and savings passed on to end users.
This includes the value applied to reduce out-of-pocket costs for insured individuals.
Also rebates collected based on patient utilization in New Hampshire for the prior year.
File annual or quarterly due Mar. 15, 2025 via PBM Annual Rebate Summary template.
Insurer and PBM Deadlines
The first deadline for insurers is on Mar. 1, 2025; for PBMs, Mar. 15, 2025.
