Judy Kamens Employee Benefits Compliance Specialist View Bio

To see the document, click here: Prescription Drug Reporting (RxDC) – Due June 1, 2025

To promote transparency in prescription drug pricing and healthcare spending, The Consolidated Appropriations Act (CAA) requires group health plans and health insurance issuers offering group or individual health insurance coverage to submit detailed information about prescription drugs and health care spending to the Departments of Labor, Treasury, and Health and Human Services.  The first reports, covering 2020 and 2021 calendar years, were due by December 27, 2022 and annually thereafter each June 1st.  The report, known as the RxDC report, contains plan files, data files, and narrative responses and is submitted through the RxDC module in the Health Insurance Oversight System (HIOS).  The next RxDC report for all group health plans is due June 1, 2025, covering 2024 calendar year data.

Employer sponsored group health plans may satisfy their reporting obligation by having a third party such as a carrier, TPA, and/or PBM submit some or all of the required information on their behalf (pursuant to a written agreement).  Where an applicable third party is only providing partial information to CMS, the group health plan sponsor will be responsible for reporting the remainder of the data.  Many carriers, TPAs, and PBMs have already reached out to group health plan sponsors notifying them what information they will be reporting and requesting certain plan level data to be submitted to them, such as average  monthly premiums (or premium equivalents) paid by member and employer.  These information requests have very tight deadlines that group health plans must adhere to.  Employers who have not already heard from their carrier, TPA, or PBM should reach out to them as soon as possible to verify what files they will be reporting on their behalf as well as what information they will need to complete the reporting and the deadline for furnishing the information.  

CLICK HERE for a summary of the requirements.

Detailed information regarding the prescription drug data collection can be found on the CMS website at https://www.cms.gov/cciio/programs-and-initiatives/other-insurance-protections/prescription-drug-data-collection , including the following:

For questions and to verify reporting responsibility and information needed, please contact your carrier, TPA or PBM or feel free to reach out to your Lawley Account Executive.