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Prescription Drug Reporting Submission Grace Period

Prescription Drug Reporting Submission Grace Period

1.5 minute read

The No Surprises Act’s transparency provisions require employer-sponsored health plans and issuers to provide 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 RxDC report was required to be submitted by December 27, 2022.


Submission Grace Period

The Departments of Labor, Health and Human Services and the Treasury (Departments) stated in an FAQ that they will not take any enforcement action against a plan or issuer that makes a good faith, reasonable interpretation of the regulations and reporting instructions in making their 2020 and 2021 data submissions by December 27, 2022.

The Departments are also providing a submission grace period through January 31, 2023. They will not consider a plan or issuer out of compliance provided that a good faith submission of 2020 and 2021 data is made on or before that date.


Employer Compliance Steps

Most employers will rely on their carriers, TPAs, or third parties to report their prescription drugs costs by the deadline. Employers may need to update their written agreements with these parties to reflect that responsibility and confirm timely reports will be submitted. Download the bulletin for more details.


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National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.

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Steve Smith

Steve Smith

Steve Smith, Employee Benefits Consultant for National Insurance Services, has his energy level permanently set at “high.” His maxim is “work hard, play hard.” Steve’s an expert in getting groups of people working together for a higher cause. Minnesota schools, cities, and counties rely on Steve’s unique and creative ideas of engaging employees in their own health and wellness to lower utilization trends. He has 20+ years in the health insurance field doing compliance, cost mitigation, utilization, analytics, wellness plans, and strategic planning. Steve is a licensed insurance agent and holds the designations for Managed Healthcare Professional (The Health Insurance Association of America), Certified Patient Protection and Affordable Care Act Professional (National Association of Health Underwriters), and Group Benefits Disability Specialist (Hartford School of Insurance). He specializes in Employee Benefits Consulting for Minnesota schools, cities, and counties including fully insured, self-insured, and stop-loss plans.