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Part of the 2021 Consolidated Appropriations Act is a new transparency provision. This provision requires employer-sponsored health plans and issuers to provide annual report information regarding health care spending and prescription drugs to the federal government. The reporting process is called the prescription drug data collection or RxDC report for short.
The first RxDC report is due December 27, 2022, covering data from 2020 and 2021. The second RxDC report is due June 1, 2023, covering data from 2022. The annual deadline is June 1 of the calendar year immediately following the reference year.
This reporting requirement applies to both fully insured and self-funded employer-sponsored health plans. Account-based plans like HRAs are exempt from the reporting.
Most employers will rely on their third-party administrators (TPAs), pharmacy benefit managers (PBMs), or issuers to provide the RxDC report for their health plans. Employers should update their written agreements with these third parties to reflect this reporting responsibility. Self-insured plans should also monitor their TPA’s or PBM’s compliance with RxDC, as legal responsibility would fall to them.
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