RXDC Reporting
Under the Consolidated Appropriations Act (CAA), insurance companies and employer-based health plans must submit information about prescription drugs and health care spending. This data submission is called the RxDC report. The RxDC report isn't only about prescription drugs, it also collects information about spending on health care services and premiums paid by members and employers.
In order to comply with this requirement, employers must rely heavily on vendors, TPAs and PBMs because these service providers possess the required data. Helpful information can be found on CMS’s RxDC webpage.
Which employers must comply?
CAA Section 204 applies to ALL group health plans and issuers, including small group plans, grandfathered plans, and non-ERISA governmental plans.
When is the deadline?
Required information from the reference years must be submitted no later than December 27, 2025. Each year thereafter, reporting for the prior reference year will be due by June 1st.
What data is required?
Plans and carriers must submit one plan list (P2 is used for Group Health Plans), eight data files (D1-D8), and a narrative response describing the impact of Rx drug rebates on premiums and cost-sharing. Some of the data is aggregated, but some is plan specific. Most of the information will come from TPAs, PBMs, and other vendors.
How must the information be submitted?
Employers or vendors reporting on behalf of plan sponsors must report to CMS online. The submission will be made through the prescription drug data collection RxDC module (Enterprise Portal). The reporting entity will need to establish an HIOS account.
Won’t the PBM, TPA, or carrier handle it on the employer’s behalf?
PBMs, TPAs, and carriers each have varying approaches and levels of assistance they will provide to employers.
Most fully-insured carriers will submit all files for active reference years on behalf of employers.
For self-insured plans with carved-out prescription drug arrangements, data from several unrelated entities may be required in order to fully provide all of the required data.
Some vendors may submit only portions of the reports on behalf of plans, but others may be merely providing the data so that an employer can submit it themselves to CMS.
As a result of the wide array of approaches amongst vendors, employers must confirm with both the medical TPA and prescription benefit manager (PBM) what level of assistance will be offered, and what additional plan information is necessary to report on the employer’s behalf.