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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 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.
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.