Group health plans and health insurance issuers must submit detailed information on prescription drug and health care spending to the Centers for Medicare & Medicaid Services (CMS) on an annual basis. This reporting is referred to as the “prescription drug data collection” (or “RxDC report”). The next RxDC report is due by June 1, 2025, covering data for 2024.
Action Steps
Employers will likely need to provide their insurance carriers and third-party vendors with plan-specific information, such as enrollment and premium data, to complete their RxDC submission. Employers should watch for these surveys and promptly provide the requested information. Because employers with self-funded plans are ultimately responsible for RxDC reporting, they should monitor their TPAs’ or PBMs’ compliance with this reporting requirement. Your Marshall+Sterling Account Manager can assist you in coordinating and submitting the required information.
RxDC Reporting
- Health plans and issuers are required to annually submit RxDC reports.
- Most employers rely on issuers, TPAs or PBMs to submit RxDC files for their health plans.
- If an issuer is required by written agreement to submit the RxDC report for a fully insured health plan but fails to do so, then the issuer (not the plan) violates the reporting requirements.
- The reporting liability stays with a self-insured health plan, even if a third party contractually agrees to submit the required information.
Reporting Resources
- RxDC reporting webpage (with links to reporting resources)
- Frequently Asked Questions
- Reporting instructions (updated January 2025)
- User Manual for submitting RxDC reports
- REGTAP | Registration for Technical Assistance Portal Training webinars and additional training materials
- CMS_FEPS@cms.hhs.gov CMS Help Desk
- CMS Enterprise Portal – Submitting your RxDC HIOS
Please reach out to your Marshall+Sterling Account Manager with any questions.
Please note: This Compliance Bulletin is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. ©2025 Zywave, Inc. All rights reserved
