The Ask the Analyst series is a deep dive into the data by those most familiar with the CO APCD – the analysts themselves. We’ll hear about their experiences with recent analyses and answer any pressing questions that come up. Have a question for the CIVHC Analyst Team? Email it to

Featured Project: Prescription Drug Rebates

Analyst Name: Julia Tremaroli

Julia helmed intake of the drug intake files that supported CIVHC’s recent analysis of prescription drug spending in Colorado. She worked with payers to make sure their annual submissions were on-time and met the standards established by the Data Submission Guide.

  1. What were your first steps when beginning this project?

Before collecting the data, we needed to ensure that the payers received detailed instruction on how to populate their files and submit. We developed detailed submission manuals for payers to refer to when developing their files.

  1. Were there specific considerations you needed to consider based on this data?

The prescription drug industry is complex with a lot of moving parts. Parsing out who is responsible for submitting what data, especially related to Pharmacy Benefit Managers (PBMs), Third Party Administrators (TPAs), and Administrative Services Organizations (ASOs) was really important so the final results didn’t double-count spending or rebates.

  1. What challenges did you encounter while completing this project? How did you overcome them?

So many! One of the greatest challenges with collecting drug rebate data is determining how to validate the files and prioritizing the most important checks. We could spend hours and hours on the phone with a payer to address a small issue that did not have a material impact on the analysis. With a couple of years of collecting this information under my belt, I’ve been able to understand the big picture and I’ve learned to prioritize the various validation checks to ensure we have the highest quality data possible.

Another general challenge that comes in the data intake world is that it sometimes feels like herding cats. It’s so important to rely on submission standards and implement standard procedures to ensure that the payers submit uniform data under the same expectations. Each year, we update our submission manual specific to drug rebates to try and address any issues we are finding in collection from year to year.

  1. Without delving into results, did anything surprise you about this project or the process of executing it?

Since I’ve been doing this project for a few years now, not a lot has surprised me. Generally, it’s interesting to hear how capabilities vary across the payer organizations, especially with complying to our submission standards. It surprises me that some of the largest payers cannot comply with our submission standards based on computer system limitations.

  1. What did you learn while completing this project?

Working with the payers on their submissions always teaches me something about the complexities of the health care system. There are so many different players with different roles and perspectives throughout the system, and it can be hard to keep up. It’s exciting we get to dive into the rebate space and I’m excited to explore the topic further.

View our Drug Rebate webpage to view our most recent Interactive Report and Issue Brief.