As administrator of the Colorado All Payer Claims Database (CO APCD), one of the CIVHC’s key responsibilities is continually working to improve the completeness, quality, and utility of the database. One of the most essential activities in continuing enhance the CO APCD is annual updates of the Data Submission Guide (DSG).

The DSG acts as a guide for payers to understand what data elements must be submitted and in what format. Each year, it is updated to add new data elements that will enhance or add new reporting from the CO APCD or clarify submission guidelines.

Updates to the DSG also include updates to submission manuals around non-claims data collected in the CO APCD, including data on Alternative Payment Models and prescription drug rebate costs.

CIVHC began collecting information on prescription drug rebates from payers in 2018 and produces an annual public report on prescription drug payments and rebates. However, new data files were introduced to the DSG in 2022 expanding the collection of information around prescription drug spending and rebates in support of state legislation aimed at addressing costs that continue to rise.

Creating a Prescription Drug Affordability Board

In 2021, the Colorado State Senate approved SB21-75, which established a Prescription Drug

Responsibilities of the Prescription Drug Affordability Review Board: • Collect and evaluate data on the cost of prescription drugs for Colorado consumers • Perform affordability reviews when a drug meets certain triggers outlined in statute • May set upper payment limit (UPL) on drugs the Board has deemed unaffordable o Maximum of 12/year for the first 3 years • Make policy recommendations to the General Assembly • Report annually to the Governor and General Assembly about drug prices, Board activity, and impacts on providers and pharmacies (beginning July 2023)

  Affordability Review Board (PDAB) housed within the Colorado Division of Insurance. The bill  gives the Board the responsibility of reviewing the affordability of high cost drugs and possibly setting payment limits for drugs determined to be unaffordable.

The bill names the CO APCD as a primary source of information, as requested by the payers and pharmacy benefit managers.

All payers were mandated to begin reporting the information required by the bill in September of 2022, and CIVHC provided the data to the DOI in February 2023.

New Pharmacy Data Captured in the CO APCD

While the CO APCD already contained a good deal of information required under SB21-75, the legislation introduced several pieces of information that needed to be added. DSG 13, which went into effect in 2022, introduced collection of a new annual files from payers in order to meet the established reporting requirements.

The table below shows the nine data elements legislated to be collected and reported on from the CO APCD under the banner of the PDAB. While most of the data elements (dark grey) were already feasible for CIVHC to report on based on current data being collected in the CO APCD, several (in green) could not be derived from current CO APCD data. These new data elements were included in the DSG as a separate annual file submission that payers report to CIVHC outside of their monthly submissions.

Prescription Drug Affordability Review Board Measures: 
1. Top 15 prescription drugs by volume 
2. The 15 costliest drugs by annual spend 
3. The 15 drugs with the highest year-over-year spending increase 
4. Top 15 drugs with the highest impact on premiums (data collected in PDAB annual file) 
5. Top 15 drugs with rebates that were most frequently paid for (data collected in PDAB annual file) 
6. The 15 drugs with the highest rebates by % (data collected in PDAB annual file) 
7. The 15 drugs with the largest rebates by $ (data collected in PDAB annual file) 
8. Total spending for each of the following categories:
		a. Brand name drugs from retail pharmacies 
		b. Authorized generics from retail pharmacies
		c. Brand name drugs from retail pharmacies 
		d. Authorized generics from mail-order pharmacies 
		e. Prescription drugs administered in an inpatient hospital setting 
9. Same measures as #8 above but for market 
		a. Individual
		b.. Small employer market
		c. Large employer market

As CIVHC collected and verified the first PDAB annual data files in the fall of 2022, the intake team worked closely with payers to familiarize them with the new processes and identify parts of the legislated reporting that need further definition. CIVHC incorporated suggestions from payers on what submitted data fields needed clarification or correction into DSG 14, which went into effect in 2023.

CIVHC is still in the process of collaborating with payers to verify the quality of submitted files and ensure timely, accurate reporting, and will continue to introduce additional corrections and refinements to collected data elements in future annual DSG changes.

Like other non-claims data collected by CIVHC, the PDAB reporting will continue to be collected on an annual basis. Per the rule change requirement for this new information, the data will only be reported directly to DOI and will not be available in non-public reports provided by CIVHC.

If you have questions or want more information on prescription drug data collected in the CO APCD, you can reach us at