Group health plans and health insurance issuers must annually submit detailed information on prescription drug and healthcare spending to the Centers for Medicare and Medicaid Services (CMS). This reporting is referred to as the prescription drug data collection (RxDC report). The next RxDC report is due by June 1, 2026, covering data for 2025.
The RxDC report includes multiple files with plan-level details (plan year dates, enrollment, premiums) and medical and pharmacy data. Reporting instructions remain essentially the same as for the 2025 filing.
Most employers rely on third parties, such as issuers, third-part administrators (TPAs), and pharmacy business managers (PBMs), to file RxDC reports. Multiple vendors can submit different sections, and the filing is considered complete once CMS has all required files.
Action Items
Employers should connect with their issuers, TPAs, and PBMs now to confirm they will file their RxDC reports by June 1, 2026. Employers should also confirm that their written agreements clearly address this reporting responsibility.
Employers will likely need to provide plan-specific information to their vendors to complete their RxDC filing. Self-funded employers are ultimately responsible for RxDC reporting and should monitor their TPAs’ or PBMs’ compliance with reporting. For the latest guidance, visit CMS’s RxDC website. Download the bulletin for more details.
