What is Prescription Drug Data Collection (RxDC) Reporting?
Under Section 204 (of Title II, Division BB) of the Consolidated Appropriations Act, 2021 (CAA), insurance companies and employer-based health plans must submit information about prescription drugs and health care spending. This data submission is called the Prescription Drug Data Collection Reporting, also referred to as RxDC Reporting.
In addition to collecting information about prescription drugs, it also reports on information about health care services spending and premium paid by employers and members.
CAA Prescription Drug Reporting is required to be submitted annually no later than June 1stto the Centers for Medicare and Medicaid Services (CMS).
Who is responsible for Prescription Drug Data Collection (RxDC) Reporting?
Fully-Insured Groups
For fully-insured groups, carriers are largely taking on the responsibility of reporting, but employers must still ensure that the carrier is filing on their behalf. It is important for plan sponsors to keep any written communication from the carrier that states how they are complying with the reporting requirement on behalf of fully-insured plans.
Self-Insured Groups / Level-Funded Plans
Self-insured groups, including level-funded plans, have more responsibility in ensuring the reporting is completed. We recommend that self-insured (and level-funded) plan sponsors contact their carrier, TPA and/or PBMs to ensure how these vendors can assist with the reporting requirement.
Self-insured plans may enter into a written agreement with their vendors to fulfill the reporting function on behalf of the plan; however, the plan sponsor remains liable for any failures.
Prescription Drug Data Collection Reporting (RxDC) Requirements by Carrier
Reference Year 2023 Reporting is Due June 1, 2024
Each carrier may have different guidelines and details for how they are handling RxDC reporting. For your reference, we have prepared the carrier RxDC reporting chart below which outlines carrier-specific guidelines and resources.
CARRIER | REPORTING FULLY-INSURED | REPORTING SELF/LEVEL-FUNDED | EMPLOYER SURVEYS | RESOURCES |
AETNA | In 2024, Aetna will require the following data from all plan sponsors included in Aetna’s D1 file: • Total premium paid by members for the reference year • Total premium paid by employer for the reference year • Funding Arrangement • Issuer Name/Legal Entity | In 2024, Aetna will require the following data from all plan sponsors included in Aetna’s D1 file: • Total premium paid by members for the reference year • Total premium paid by employer for the reference year • Funding Arrangement • Issuer Name/Legal Entity If a self-insured plan sponsor requests to be excluded from Aetna’s D1 file, you do not need to complete this data collection process. Instead, plan sponsors should contact their account representative to request an exception. | Data Collection Requirement for RxDC Reporting Submission Complete the fields provided in the emailed form no later than 4/12/2024. |
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AMERIHEALTH NJ | Carrier will report. | AmeriHealth will produce and submit the D1 file, as a service to our self-funded customers, based on the data AmeriHealth currently has within its systems for the timeframes required for the reports. For the June 1, 2024, and subsequent Section 204 – RxDC submission to CMS, AmeriHealth will collect information for Form 5500 Plan Code, the employee contribution information, and the PBM name through the Employer Portal. | No survey is required. Will collect information for Form 5500 Plan Code, the employee contribution information, and the PBM name through the Employer Portal. | |
ANTHEM NY | Fully-Insured clients must complete the emailed survey, which includes EE/ER percentages by 3/15. | ASO clients must complete the opt in survey by 3/15 if they want Anthem to file D1 on their behalf. See resources for additional information. | ||
ANTHEM CT | Carrier will report. Will require additional information from clients via survey. They will be sending out notifications starting 2/7 that will include a link to a survey which has to be completed & returned by 3/15/24. | Carrier will report. Will require additional information from clients via survey. They will be sending out notifications starting 2/7 that will include a link to a survey which has to be completed & returned by 3/15/24. | Details pending for 2024. |
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CAREFIRST BCBS | Employer must report:
Carrier will report:
| Employer must report:
Carrier will report:
| No survey is required. |
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CIGNA | Carrier will report. | Carrier will report. | No survey is required. |
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CIGNA + OSCAR | Carrier will report. | N/A | No survey has been announced. |
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CIGNA ADMINISTERED BY OSCAR | Carrier will report. | N/A | No survey has been announced. |
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CONNECTICARE | Carrier will report. | N/A | Details pending for 2024. |
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EMBLEMHEALTH | Carrier will report. | Carrier will report. | Details pending for 2024. | |
FLORIDA BLUE | Carrier will report. Will require additional information from clients via survey. | Carrier will report. Will require additional information from clients via survey. | Complete survey questions by March 1st, 2024. |
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HORIZON BCBSNJ | Carrier will report. | Carrier will report. Will not collect external carrier files to aggregate data. Will not submit D3-D8 Pharmacy data files if Prime Therapeutics is not the designated PBM. | No survey is required. | |
HUMANA | Carrier will report. Will require additional information from clients via survey. | Varies; refer to Humana's Prescription Drug Data Guide. | Will be sending health plan sponsors an online survey early February 2024. | |
INDEPENDENCE BLUE CROSS (IBC) | Carrier will report. For the June 1, 2024, and subsequent Section 204 – RxDC submission to CMS, Independence will collect information for Form 5500 Plan Code, the employee contribution information, and the PBM name through the Employer Portal. | Carrier will report. For the June 1, 2024, and subsequent Section 204 – RxDC submission to CMS, Independence will collect information for Form 5500 Plan Code, the employee contribution information, and the PBM name through the Employer Portal. | No survey is required. | |
INDEPENDENCE ADMINISTRATORS (IA) | N/A | Carrier will report. Will produce and submit files P2, D1 and D2, as a service to our self-funded customers, based on the data IA currently has within its systems for the timeframes required for the reports. If the self-funded client has Optum Rx as their PBM, Optum Rx will provide the files D3 through D8 to IA. IA will submit all files to CMS in one ‘reporting’ package. For self-funded customers with coverage through a different PBM, data for the D3 through D8 files will not be included. | No survey is required. | |
OSCAR | Carrier will report. | N/A | No survey has been announced. |
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UNITEDHEALTHCARE OXFORD | Carrier will report for groups using OptumRx as PBM. Groups with other PBMs (including OptumRx Direct) should refer to the CAA UHC Approach to Pharmacy Benefits and Costs Reporting Guide. | Carrier will report for groups using OptumRx as PBM. ASO groups and groups with other PBMs (including OptumRx Direct) should refer to the CAA UHC Approach to Pharmacy Benefits and Costs Reporting Guide. |
| Any group that does not have a Surest or UMR policy will use the first UHC RFI link regardless of group segment or whether they are fully-insured vs. level-funded. The UMR link and Surest link are for large groups (51+) that have a UMR or Surest policy. The deadline for employers to complete the UHC or Surest RFIs is April 10, 2024. The deadline for employers to complete the UMR RFI is March 31, 2024 Additional resources: |
For further details, visit the CMS CAA Prescription Drug Reporting (RxDC) resources below.
If you have any questions, our team is here to help. Contact us today.