Prescription Drug Data Collection (RxDC) Reporting Carrier Guidelines

The Consolidated Appropriations Act, 2021 (CAA) requires health plan sponsors to submit detailed information on prescription drug expenses and coverage reports to CMS annually by June 1st.

Published: 03.02.2026

What is Prescription Drug Data Collection (RxDC) Reporting?

Under Section 204 (of Title II, Division BB) of the Consolidated Appropriations Act, 2021 (CAA), insurance companies and employer-based health plans must submit information about prescription drugs and health care spending. This data submission is called the Prescription Drug Data Collection Reporting, also referred to as RxDC Reporting.

In addition to collecting information about prescription drugs, it also reports on information about health care services spending and premium paid by employers and members.

CAA Prescription Drug Reporting is required to be submitted annually no later than June 1^st to the Centers for Medicare and Medicaid Services (CMS).

Who is responsible for Prescription Drug Data Collection (RxDC) Reporting?

Fully-Insured Groups

For fully-insured groups, carriers are largely taking on the responsibility of reporting, but employers must still ensure that the carrier is filing on their behalf. It is important for plan sponsors to keep any written communication from the carrier that states how they are complying with the reporting requirement on behalf of fully-insured plans.

Self-Insured Groups / Level-Funded Plans

Self-insured groups, including level-funded plans, have more responsibility in ensuring the reporting is completed. We recommend that self-insured (and level-funded) plan sponsors contact their carrier, TPA and/or PBMs to ensure how these vendors can assist with the reporting requirement.

Self-insured plans may enter into a written agreement with their vendors to fulfill the reporting function on behalf of the plan; however, the plan sponsor remains liable for any failures.

Prescription Drug Data Collection Reporting (RxDC) Requirements by Carrier

Reference Year 2025 Reporting is Due June 1, 2026

Each carrier may have different guidelines and details for how they are handling RxDC reporting. For your reference, we have prepared the carrier RxDC reporting chart below which outlines carrier-specific guidelines and resources.

If a carrier survey remains open after the deadline, there is no guarantee that the information will be received by the carrier.

CARRIER	REPORTING FULLY-INSURED	REPORTING SELF/LEVEL-FUNDED	EMPLOYER SURVEYS	RESOURCES
Aetna	Aetna is committed to complying with all legal and regulatory requirements affecting their business operations and customer's health benefits. The following is how Aetna is helping their Small Group plan sponsors submit these reports. The submission process Starting February 2nd, Aetna will send an email to all Small Group plan sponsors with instructions on how to submit the required data. Clients should fill out the RxDC Plan Sponsor Data Collection Form with the required data by 3/31/2026. Required data: Average monthly premium paid by members Average monthly premium paid by employer Broker Submission Option: you may use this form to provide the information to Aetna on behalf of your client Aetna Prescription Drug Data Collection We can then use the data to submit on behalf of your client. Process for submissions that are missing or incomplete by 3/31/2026 We will submit the report without the required plan sponsor data. Failure to respond will impact our ability to accurately report on the plan sponsor’s behalf, and Aetna will not be responsible for any liability associated with the inaccurate report. What you can do: Help your clients gather and report the data so they won’t have anything else to worry about. Aetna RxDC Reporting Full Release	Aetna is committed to complying with all legal and regulatory requirements affecting their business operations and customer's health benefits. The following is how Aetna is helping their Small Group plan sponsors submit these reports. The submission process Starting February 2nd, Aetna will send an email to all Small Group plan sponsors with instructions on how to submit the required data. Clients should fill out the RxDC Plan Sponsor Data Collection Form with the required data by 3/31/2026. Required data: Average monthly premium paid by members Average monthly premium paid by employer Broker Submission Option: you may use this form to provide the information to Aetna on behalf of your client Aetna Prescription Drug Data Collection We can then use the data to submit on behalf of your client. Process for submissions that are missing or incomplete by 3/31/2026 We will submit the report without the required plan sponsor data. Failure to respond will impact our ability to accurately report on the plan sponsor’s behalf, and Aetna will not be responsible for any liability associated with the inaccurate report. What you can do: Help your clients gather and report the data so they won’t have anything else to worry about. Aetna RxDC Reporting Full Release	Starting February 2nd, Aetna will send an email to all Small Group plan sponsors with instructions on how to submit the required data. Clients should fill out the RxDC Plan Sponsor Data Collection Form with the required data by 3/31/2026. Required data: Average monthly premium paid by members Average monthly premium paid by employer	Broker Submission Option: you may use this form to provide the information to Aetna on behalf of your client Aetna Prescription Drug Data Collection Aetna RxDC Reporting Full Release
AmeriHealth NJ	Pending Carrier Response
Anthem (CT, NY)	The Prescription Drug Data Collection reporting provision of the Consolidated Appropriations Act (CAA) requires reports on drug utilization and spending trends be submitted to the U.S. Department of Health and Human Services. As a reminder, we are required to include information in the average monthly premium paid by member and by employer in the Premium and Life Years (D1) reporting. To make sure your data is included in our aggregate filing for calendar year 2025 data, please complete this form before March 25, 2026. We must receive this data for you and us to avoid non-compliance.	The Prescription Drug Data Collection reporting provision of the Consolidated Appropriations Act (CAA) requires reports on drug utilization and spending trends be submitted to the U.S. Department of Health and Human Services. As a reminder, we are required to include information in the average monthly premium paid by member and by employer in the Premium and Life Years (D1) reporting. To make sure your data is included in our aggregate filing for calendar year 2025 data, please complete this form before March 25, 2026. We must receive this data for you and us to avoid non-compliance.	To make sure your data is included in our aggregate filing for calendar year 2025 data, please complete this form before March 25, 2026. We must receive this data for you and us to avoid non-compliance.
BCBS of North Carolina (Blue Cross NC)	Pending Carrier Response
CareFirst BCBS	Pending Carrier Response		.
Cigna	Pending Carrier Response
Cigna + Oscar	Pending Carrier Response
Cigna Administered by Oscar	Pending Carrier Response
ConnectiCare	Pending Carrier Response
EmblemHealth	Pending Carrier Response
Florida Blue	For the 2026 reporting phase, Florida Blue will collect necessary data from our employer groups through an external survey vendor (Qualtrics). The survey will launch on February 3, 2026, and we require a response from the groups by March 15, 2026. This effort demonstrates our continued commitment to meeting the CAA Section 204 reporting requirements. All collected data will be submitted to CMS by June 1, 2026, ensuring timely federal compliance for the current filing year. Details On February 3, 2026, our Section 204 data collection survey will go live for employer groups to complete. Our fully insured, MPP, and self-funded employer groups will receive an email or mailed letter from Florida Blue, detailing the specific data they need to provide through the survey to ensure compliance with federal filing: Fully Insured Employer Groups Total premium amounts (in dollars) paid by the EMPLOYEE in the 2025 Calendar Year Total premium amounts (in dollars) paid by the EMPLOYER in the 2025 Calendar Year Please note: Florida Blue will report all the survey data as an aggregate for Fully Insured or Self-Insured groups. If an employer group does not respond to our survey request, their data cannot be reported to CMS by Florida Blue.	For the 2026 reporting phase, Florida Blue will collect necessary data from our employer groups through an external survey vendor (Qualtrics). The survey will launch on February 3, 2026, and we require a response from the groups by March 15, 2026. This effort demonstrates our continued commitment to meeting the CAA Section 204 reporting requirements. All collected data will be submitted to CMS by June 1, 2026, ensuring timely federal compliance for the current filing year. Details On February 3, 2026, our Section 204 data collection survey will go live for employer groups to complete. Our fully insured, MPP, and self-funded employer groups will receive an email or mailed letter from Florida Blue, detailing the specific data they need to provide through the survey to ensure compliance with federal filing: Self- Funded Employer Groups that DO NOT have Pharmacy Carveout Department of Labor (DOL) Form 5500 Plan Number (if applicable) 2025 average number of employees (including seasonal and part-time employees) Total premium amounts (in dollars) paid by the EMPLOYEE in the 2025 Calendar Year Total premium amounts (in dollars) paid by the EMPLOYER in the 2025 Calendar Year Self- Funded Employer Groups that DO have Pharmacy Carveout Pharmacy Benefit Manager (PBM) name PBM Employer Identification Number (also known as the Tax ID) Department of Labor (DOL) Form 5500 Plan Number (for ASO only) 2025 average number of employees (including seasonal and part-time employees) Total premium equivalents & administrative fees (in dollars) paid by the EMPLOYEE in the 2025 Calendar Year (Health & Pharmacy) Total premium equivalents & administrative fees (in dollars) paid by the EMPLOYER in the 2025 Calendar Year (Health & Pharmacy) Total Administrative Services Only (ASO)/ and Third-Party Administrative (TPA) Fees (in dollars) Paid in the 2025 Calendar Year (Pharmacy Only) Total Premium Equivalents (in dollars) Paid in the 2025 Calendar Year (Pharmacy Only) Please note: Florida Blue will report all the survey data as an aggregate for Fully Insured or Self-Insured groups. If an employer group does not respond to our survey request, their data cannot be reported to CMS by Florida Blue.		Florida Blue Full RxDC Release
Highmark	Section 204 of the Consolidated Appropriations Act (CAA) of 2021 mandates that data be submitted to the Centers for Medicare & Medicaid Services (CMS) regarding prescription drug spending, healthcare spending, and enrollment for the 2025 calendar year. Highmark will submit the data on behalf of its fully insured and self-funded employer group clients in compliance with this year’s deadline. We need your help to collect the necessary premium information for our mutual clients. What do I need to know? Deadline: The deadline to submit the required information is April 17, 2026, at 11:59 PM EST. Late submissions will not be accepted. Data Required: We need specific premium data for both fully insured and self-insured (ASO) clients. The exact data required differs slightly between these groups (detailed below). This data will be aggregated and reported to CMS; individual client details will not be disclosed. Fully Insured Clients: Requires average monthly premiums paid by the employer and by members for calendar year 2025. Self-Insured (ASO) Clients: Requires more comprehensive data including total premium equivalents, ASO and TPA fees, stop-loss premiums, and average monthly premiums paid by the employer and members for calendar year 2025. ASO clients with carved-out pharmacy benefits must work with their Pharmacy Benefit Managers (PBMs) to submit the necessary pharmacy benefit data files directly to CMS. Highmark will not submit this data on their behalf. Consequences of Non-Compliance: Failure to submit the required information by the deadline will result in Highmark’s inability to include your clients' data in our submission to CMS. Self-insured clients will then be responsible for submitting the required data directly to CMS. Survey Link: Direct your clients to complete the Highmark RxDC survey by clicking here . If clients need assistance, we've created the Section 204 Reporting - Highmark Client Tip Sheet 2026. What do I need to do? To ensure a high response rate for the RxDC survey, Highmark will contact clients stressing the April 17th deadline. Producers may be asked provide support as necessary.	Section 204 of the Consolidated Appropriations Act (CAA) of 2021 mandates that data be submitted to the Centers for Medicare & Medicaid Services (CMS) regarding prescription drug spending, healthcare spending, and enrollment for the 2025 calendar year. Highmark will submit the data on behalf of its fully insured and self-funded employer group clients in compliance with this year’s deadline. We need your help to collect the necessary premium information for our mutual clients. What do I need to know? Deadline: The deadline to submit the required information is April 17, 2026, at 11:59 PM EST. Late submissions will not be accepted. Data Required: We need specific premium data for both fully insured and self-insured (ASO) clients. The exact data required differs slightly between these groups (detailed below). This data will be aggregated and reported to CMS; individual client details will not be disclosed. Fully Insured Clients: Requires average monthly premiums paid by the employer and by members for calendar year 2025. Self-Insured (ASO) Clients: Requires more comprehensive data including total premium equivalents, ASO and TPA fees, stop-loss premiums, and average monthly premiums paid by the employer and members for calendar year 2025. ASO clients with carved-out pharmacy benefits must work with their Pharmacy Benefit Managers (PBMs) to submit the necessary pharmacy benefit data files directly to CMS. Highmark will not submit this data on their behalf. Consequences of Non-Compliance: Failure to submit the required information by the deadline will result in Highmark’s inability to include your clients' data in our submission to CMS. Self-insured clients will then be responsible for submitting the required data directly to CMS. Survey Link: Direct your clients to complete the Highmark RxDC survey by clicking here . If clients need assistance, we've created the Section 204 Reporting - Highmark Client Tip Sheet 2026. What do I need to do? To ensure a high response rate for the RxDC survey, Highmark will contact clients stressing the April 17th deadline. Producers may be asked provide support as necessary.	Direct your clients to complete the Highmark RxDC survey by clicking here.	Section 204 Reporting - Highmark Client Tip Sheet 2026
Horizon BCBSNJ	Pending Carrier Response
Humana	Pending Carrier Response
Independence Blue Cross (IBC)	Pending Carrier Response
Independence Administrators (IA)	Pending Carrier Response
Oscar	Pending Carrier Response
UnitedHealthcare /Oxford	UHC/Oxford: CAA’s RxDC RFI Required by 3/31/26 UnitedHealthcare/Oxford requests your support in completing a few necessary questions in the Prescription Drug Data Collection (RxDC) RFI now available on the employer/broker portals until March 31, 2026. What’s Required: All commercial Fully-Insured, Level-Funded, and Self-Funded employer groups with UnitedHealthcare (and Surest) medical coverage must complete the RxDC Request for Information (RFI) by March 31, 2026. If a self-funded client plans to submit their own data, they must notify UHC by March 31, 2026. UMR customers follow a separate process and should use the link provided by their Strategic Account Executive (SAE). Completing the RFI allows UnitedHealthcare to submit accurate RxDC data to CMS by June 1, 2026. Missing information could result in incomplete reporting and compliance risks for your clients. Note: UMR customers received a customer-specific link to an RFI in an email from their UMR Strategic Account Executive (SAE). UMR customers must also complete the RFI by the March 31 deadline. To facilitate this process for UHC customers, we recommend using the RxDC RFI worksheet to gather the required data in advance. Visit UHC's full release and resources on 2025 RxDC reporting.	UHC/Oxford: CAA’s RxDC RFI Required by 3/31/26 UnitedHealthcare/Oxford requests your support in completing a few necessary questions in the Prescription Drug Data Collection (RxDC) RFI now available on the employer/broker portals until March 31, 2026. What’s Required: All commercial Fully-Insured, Level-Funded, and Self-Funded employer groups with UnitedHealthcare (and Surest) medical coverage must complete the RxDC Request for Information (RFI) by March 31, 2026. If a self-funded client plans to submit their own data, they must notify UHC by March 31, 2026. UMR customers follow a separate process and should use the link provided by their Strategic Account Executive (SAE). Completing the RFI allows UnitedHealthcare to submit accurate RxDC data to CMS by June 1, 2026. Missing information could result in incomplete reporting and compliance risks for your clients. Note: UMR customers received a customer-specific link to an RFI in an email from their UMR Strategic Account Executive (SAE). UMR customers must also complete the RFI by the March 31 deadline. To facilitate this process for UHC customers, we recommend using the RxDC RFI worksheet to gather the required data in advance. Visit UHC's full release and resources on 2025 RxDC reporting.	To facilitate this process for UHC customers, we recommend using the RxDC RFI worksheet to gather the required data in advance.	To facilitate this process please refer to the following helpful resources: RxDC Brainshark Information video, RxDC Guide, and external RxDC FAQs about the CMS RxDC requirements and the process for you to submit data to UHC. You can watch the video at your convenience, review any information you need, and easily print out any resources for future reference.

For further details, visit the CMS CAA Prescription Drug Reporting (RxDC) resources below.

If you have any questions, our Employer Services and Compliance Team is here to help. Contact us today.

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