Prescription Drug Data Collection (RxDC) Reporting Carrier Guidelines

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 1st to 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 2024 Reporting is Due June 1, 2025

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
AETNA	All small group clients should have received an email with instructions on how to submit the required data. Clients should complete the RxDC Plan Sponsor Data Collection Form no later than March 31, 2025. If preferred, the broker may submit the Form to Aetna on behalf of your client. Follow this link https://pss.tfaforms.net/122 to do so. Note: Aetna will submit the report even if they are missing required data. Failure to submit the required information to Aetna by March 31, 2025, will impact their ability to accurately report on behalf of the clients. Aetna will not be responsible for any liability associated with an inaccurate report. Starting Friday, January 31, Aetna will begin emailing plan sponsors to collect information for this years report. In 2025, 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	Starting Friday, January 31, Aetna will begin emailing plan sponsors to collect information for this years report. In 2025, 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 arrangmenet Issuer Name/Legal Entity If a self-insured plan sponsor requests to be excluded from Aetna’s D1 file, employers do not need to complete this data collection process. Instead, plan sponsors should contact their account representative to request an exception.	Survey must be completed by March 31, 2025. If any plan sponsor does not provide the requested data by March 31, Aetna will submit the report without the required plan sponsor data. Failure to respond with complete and correct information will impact Aetna's ability to accurately report on the plan sponsor’s behalf, and Aetna will not be responsible for any liability associated with the inaccurate report. It may be necessary for the employer to submit this information to CMS directly.
AMERIHEALTH NJ	Customers must submit their data through via online form by May 1, 2025. NOTE: Survey should be submitted by midnight 4/30/2025 to be received by the carrier on 5/1/2025.	Customers must submit their data through via online form by May 1, 2025. NOTE: Survey should be submitted by midnight 4/30/2025 to be received by the carrier on 5/1/2025.	RxDC Survey form
ANTHEM NY	Anthem will email Fully Insured National Account, Large Group, and Small Group commercial clients, as well as clients with Minimum Premium, MEWA, and Anthem Balanced Funding plans the week of February 17.  The email will include a link to an online form for these clients to provide the information Anthem needs to complete the filings on their behalf.	Anthem will email Fully Insured National Account, Large Group, and Small Group commercial clients, as well as clients with Minimum Premium, MEWA, and Anthem Balanced Funding plans the week of February 17.  The email will include a link to an online form for these clients to provide the information Anthem needs to complete the filings on their behalf.	Survey will be provided in email from carrier.
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.
BCBS OF NORTH CAROLINA (BLUE CROSS NC)	Pending carrier response.	Pending carrier response.	Pending carrier response.
CAPITAL BLUE CROSS	Pending carrier response.	Pending carrier response.	Pending carrier response.
CAREFIRST BCBS	CareFirst will annually submit all RxDC files* on behalf of our fully insured clients and our self-insured clients that are not contracted under a Shared Processing Services Agreement or Network Lease Agreement. CareFirst will submit data for all applicable clients that contracted with us for any portion of the reference year. *Certain client data will only be included on the D1 Premium and Life-Years file submission if any request for that data is provided by the deadline provided at the time of the request. In lieu of providing the data, clients will have an option to opt out of having CareFirst submit their D1 data.	CareFirst will annually submit all RxDC files* on behalf of our fully insured clients and our self-insured clients that are not contracted under a Shared Processing Services Agreement or Network Lease Agreement. CareFirst will submit data for all applicable clients that contracted with us for any portion of the reference year. *Certain client data will only be included on the D1 Premium and Life-Years file submission if any request for that data is provided by the deadline provided at the time of the request. In lieu of providing the data, clients will have an option to opt out of having CareFirst submit their D1 data.	No survey is required.
CIGNA	As part of the aggregated information in the Cigna Healthcare submission for 6/1/2025, clients will be asked to verify or update their employer contribution percentage (across all medical plans) during their renewal process. To comply with the CAA section 204 final rule, Cigna Healthcare is submitting files on our clients’ behalf. We submit these files at no additional cost to the clients. This is the standard option for ASO and fully insured clients. As an ASO client you may choose to opt out of our standard offering, however, we believe that there are compelling reasons for you to leverage the Cigna Healthcare standard offering.	As part of the aggregated information in the Cigna Healthcare submission for 6/1/2025, clients will be asked to verify or update their employer contribution percentage (across all medical plans) during their renewal process. To comply with the CAA section 204 final rule, Cigna Healthcare is submitting files on our clients’ behalf. We submit these files at no additional cost to the clients. This is the standard option for ASO and fully insured clients. As an ASO client you may choose to opt out of our standard offering, however, we believe that there are compelling reasons for you to leverage the Cigna Healthcare standard offering.	No survey is required.
CIGNA + OSCAR	Carrier will report.	N/A	No survey has been announced.
CIGNA ADMINISTERED BY OSCAR	Carrier will report.	N/A	No survey has been announced.
CONNECTICARE	Carrier will report.	N/A	Details pending for 2025.
EMBLEMHEALTH	Carrier will report. Will require additional information from clients via survey.	Carrier will report. Will require additional information from clients via survey.	Survey will be sent to all group clients in April 2025 to collect this required data.
FLORIDA BLUE	Carrier will report. Will require additional information from clients via survey.	Carrier will report. Will require additional information from clients via survey.	To facilitate this process, there are three distinct surveys tailored to your specific group type:  Fully Insured, MPP, and ASO/Self-Insured groups.  You will receive an email with a unique link to access your designated survey. The survey will contain pre-populated information that we ask you to review and confirm. If any information is incorrect, you will have the opportunity to update it with the correct details.
HIGHMARK	Fully insured clients and ASO clients that would like Highmark to submit premium data to CMS on their behalf must submit all of the required information to Highmark by no later than April 14, 2025 via the Highmark Prescription Drug Data Collection (RxDC) Survey. Fully Insured Clients: All fully insured group health plan clients must submit the (1) average monthly premium amounts paid by the employer, and (2) average monthly premium amounts paid by members in calendar year 2024 by no later than Monday, April 14, 2025 via this Highmark Survey. Please note that the premium information collected will be reported on an aggregated basis – premium details will not be broken out by individual clients. Highmark will incorporate the premium information provided by fully insured clients into our aggregated reporting package.	Self-Insured (ASO) Clients: ASO clients that would like Highmark to submit premium data to CMS on their behalf must submit all of the required information to Highmark by no later than Monday, April 14, 2025, via this Highmark Survey. Please note that the premium information collected will be reported on an aggregated basis – premium details will not be broken out by individual clients. If the client does not complete the survey by the deadline, they will be responsible for the submission of the premium data file (D1) and corresponding plan file (P2) directly to CMS. Please note that ASO clients with carved-out pharmacy benefits will need to work with their PBMs to submit the data files specific to the pharmacy benefit (D3 - D8). This is the same approach that was followed for the calendar year 2023 submission.	Fully insured clients and ASO clients that would like Highmark to submit premium data to CMS on their behalf must submit all of the required information to Highmark by no later than April 14, 2025 via the link https://youropinionmatters.alidainsights.com/rsp/d54e8c3d-6dfd-7735-5af2-c7647508cc5aFrom a requirements standpoint, CMS requires that data submitted in files D1 and D3 – D8 must not be aggregated at a less granular level than the aggregation level used by the reporting entity that submitted the data in file D2 Spending by Category. When more than one reporting entity is submitting D2 on behalf of the same plan, issuer, or carrier, the reporting entity that submitted D2 at the most granular level shall serve as the aggregation level to use solely for the aggregation restriction. Highmark will be aggregating at the Issuer / TPA Level.
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.	Carrier will report.	Pending survey.
INDEPENDENCE BLUE CROSS (IBC)	Customers must submit their data through via online form by May 1, 2025. NOTE: Survey should be submitted by midnight 4/30/2025 to be received by the carrier on 5/1/2025	Customers must submit their data through via online form by May 1, 2025. NOTE: Survey should be submitted by midnight 4/30/2025 to be received by the carrier on 5/1/2025	RxDC Survey form
INDEPENDENCE ADMINISTRATORS (IA)	Pending response.	Pending response.	Pending response.
OSCAR	Pending response.	Pending response.	Pending response.
UNITEDHEALTHCARE OXFORD	Groups should use the RFI tool found on uhceservices.com to submit their information to us by the 3/31/25 deadline. If the deadline is missed, UHC will submit the data available that we have, but it will still be considered incomplete and the group will need to submit directly in to CMS themselves.	Groups should use the RFI tool found on uhceservices.com to submit their information to us by the 3/31/25 deadline. If the deadline is missed, UHC will submit the data available that we have, but it will still be considered incomplete and the group will need to submit directly in to CMS themselves.	No survey is required.
UPMC	Health Plan will reach out in late February 2025 to collect applicable data from your group.	Health Plan will reach out in late February 2025 to collect applicable data from your group.	Pending response.

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