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RxDC Reports Must Be Submitted by June 1, 2025

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1.5 minute read

Group health plans and insurers must submit the annual RxDC report on prescription drug and healthcare spending to the federal government by June 1st of each year. The upcoming report, due June 1, 2025, will cover 2024 data. Employers should ensure timely compliance by coordinating with third-party vendors.

 

RxDC Reporting

RxDC reporting is mandatory for all group health plans, including fully insured, self-insured, and level-funded plans. These reports, submitted via the Centers for Medicare and Medicaid Services (CMS) online portal, require specific plan-level details such as plan year dates, enrollment, premium data, and comprehensive medical and pharmacy benefits information. The CMS’ RxDC website provides reporting instructions and resources.

 

Using Third Parties to Submit RxDC Files

Employers often rely on third parties like issuers, third-party administrators (TPAs), and pharmacy benefit managers (PBMs) to submit RxDC reports for their health plans. It's crucial that this responsibility is clearly outlined in a written agreement with the third party.

Interim final rules state that if a fully insured group health plan issuer fails to submit the RxDC report, the issuer—not the plan—violates the requirements. For self-funded plans, the responsibility remains with the employer, even if a third party handles the report. Employers should ensure their TPAs or PBMs comply with this obligation.

Employers must provide plan-specific data, like enrollment and premiums, to third-party vendors for RxDC submissions. They may collaborate with multiple vendors, such as TPAs and PBMs, to complete the report. A submission is complete once CMS receives all necessary files, regardless of who submits them. 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 is a powerhouse of energy, living by the mantra "work hard, play hard." As an expert in uniting teams for a greater purpose, Steve's innovative and creative strategies in employee health and wellness are game-changers. With over 25 years of expertise in health insurance, covering compliance, cost mitigation, utilization, analytics, wellness plans, and strategic planning, Steve is the go-to expert for driving down utilization trends and fostering a culture of well-being. His clients trust him to deliver exceptional results, making him an invaluable asset in the industry. As an Employee Benefits Consultant, Steve specializes in health care consulting for Minnesota public sector organizations including fully insured, self-insured, and stop-loss plans. 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).