Health plans and insurance issuers must submit annual prescription drug data collection (RxDC) reports to the federal government. The next deadline is Sunday, June 1, 2025, covering 2024 data.
Who Must Report
All group health plans must comply, including:
- Fully insured plans
- Self-insured plans
- Level-funded plans
Report Contents
The RxDC report includes multiple files containing:
- Plan-specific information (plan year dates, enrollment data)
- Premium information
- Detailed medical and pharmacy benefits data
Submission Process
Reports must be submitted through the Centers for Medicare and Medicaid Services (CMS) online portal. Updated instructions and resources are available on the CMS RxDC website.
Using Third-Party Vendors
Most employers use third parties (insurers, TPAs, PBMs) to submit reports. Key considerations:
- This arrangement should be documented in a written agreement
- For fully insured plans: If the insurer agrees to report but fails, the insurer (not the plan) violates requirements
- For self-funded plans: The plan retains legal responsibility even when a third party submits the report
- Multiple vendors may submit different portions of a plan’s complete report
Employer Action Items
- Confirm with vendors who will submit files for your plan
- Promptly provide requested information to these vendors
- Update written agreements to include RxDC reporting responsibilities
- For self-insured plans, verify vendor compliance with reporting requirements
Employers should ensure timely submission of plan-specific information to vendors to meet the June 1, 2025 deadline.