"Employers that sponsor a health plan can require their health insurance companies(for fully-insured products), and TPAs (for self- funded health plans), and PBMs, to make the data submission to HHS on behalf of the Employer Plan Sponsors. The request can be manifested in a written agreement. The regulations also allow the prescription pricing data to be submitted separately by a 'reporting entity', which is an entity other than or in addition to the Plan Sponsor."  MORE >>