Each year, group health plans and issuers must submit a Prescription Drug Data Collection (RxDC) report to the federal government by June 1, detailing the prior calendar year’s prescription drug and healthcare spending. The next RxDC report is due June 1, 2026, for 2025 data. Employers should ensure they are working with their vendors now to provide the information needed to meet this deadline.
RxDC Reporting
RxDC reporting applies to all group health plans including fully insured, self-insured, and level-funded. Reports, submitted through the Centers for Medicare and Medicaid Services (CMS) online portal, include plan-level details (plan year dates, enrollment, premiums) and medical and pharmacy benefit data. CMS’ RxDC website provides current instructions and FAQs, with no major changes from the 2025 reporting cycle.
Using Third Parties to Submit RxDC Files
Many employers rely on trusted partners such as issuers, third-party administrators (TPAs), and pharmacy benefit managers to handle RxDC reporting for their health plans. For employers delegating this task, be sure the responsibility and deadlines are clearly outlined in a written agreement, so nothing falls through the cracks.
For fully insured plans, if a written agreement assigns RxDC reporting to the carrier and the carrier fails to file, the carrier, not the plan, violates the rules. For self-insured plans, the legal responsibility always stays with the plan sponsor, even when a TPA or pharmacy benefit manager (PBM) files on their behalf, so employers should actively monitor their vendors’ compliance.
To complete RxDC reporting, employers will need to share plan-specific data with their vendors. Multiple vendors can submit different sections (for example, a TPA and a PBM for a self-insured plan), and CMS considers the filing complete once all required files are received, regardless of who submits them. Download the bulletin for more details.
