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: 04.26.2024
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 1st 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 2023 Reporting is Due June 1, 2024
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.| CARRIER | REPORTING FULLY-INSURED |
REPORTING SELF/LEVEL-FUNDED |
EMPLOYER SURVEYS | RESOURCES |
|---|---|---|---|---|
| Aetna | Carrier will report. | AFA groups carrier will report. If a self-insured plan sponsor requests to be excluded from Aetna’s D1 file, the plan sponsor does not need to complete this data collection process. Instead, plan sponsors should contact their Aetna account representative to request an exception and will be required to report the D1 file information to CMS directly. Self-Insured Large Groups: details pending, check with the large group Aetna representative. |
Required survey: Data Collection Requirement for RxDC Reporting Submission Plan sponsors must complete the fields provided in the survey form no later than 4/12/24. If any plan sponsor does not provide the requested data for the D1 file by 4/12/24, Aetna will submit the report without the required plan sponsor data. It will be necessary for the employer to submit this information to CMS directly. In 2024, Aetna will require the following data from all plan sponsors included in Aetna’s D1 file: • Total premium paid by members for the reference year • Total premium paid by employer for the reference year • Funding Arrangement • Issuer Name/Legal Entity |
|
| AmeriHealth NJ | Carrier will report if the survey is completed online. AmeriHealth/ AmeriHealth Administrators will submit all files including P2, D1, and D2-D8 on behalf of insured customers to CMS in one reporting package based on the data they currently have within their systems for the timeframes required for the reports. |
Carrier will report if the survey is completed online. AmeriHealth/ AmeriHealth Administrators will produce and submit files P2, D1, and D2 for self-funded customers based on the data they currently have within their systems for the timeframes required for the reports. Important Notes: If a self-funded customer has OptumRx as their PBM, OptumRx will provide files D3 through D8 to AmeriHealth/ AmeriHealth Administrators. For self-funded customers that carve out prescription drug benefits, data for files D3 through D8 will not be included. AmeriHealth/ AmeriHealth Administrators will submit all files to CMS in one reporting package. |
To obtain the employee contribution information, AmeriHealth/ AmeriHealth Administrators will be requesting the information via this online form, due May 1, 2024. Information collected will include: Yearly total employee contribution based on the type of product the customer offers (HMO or PPO). For self-funded customers who submit Form 5500, the Form 5500 plan number. For self-funded customers that carve out prescription drug benefits, the pharmacy benefit manager (PBM) name and EIN. |
AmeriHealth CAA and TCR RxDC Information 2024 AmeriHealth Prescription Drug Data Collection (RxDC) |
| Anthem NY | Fully-Insured clients must complete the emailed survey, which includes EE/ER percentages by 3/15. | ASO clients must complete the opt in survey by 3/15 if they want Anthem to file D1 on their behalf. See resources for additional information. |
Fully-Insured Data Form 2024 ASO Data Form 2024 |
Fully-Insured email template ASO email template |
| Anthem CT | Carrier will report. Will require additional information from clients via survey. They will be sending out notifications starting 2/7 that will include a link to a survey which has to be completed & returned by 3/15/24. |
Carrier will report. Will require additional information from clients via survey. They will be sending out notifications starting 2/7 that will include a link to a survey which has to be completed & returned by 3/15/24. |
Details pending for 2024. | |
| BCBS of North Carolina (Blue Cross NC) |
Fully-Insured clients must complete the emailed survey and submit electronic by the requested deadline April 15, 2024 | Employer must report | RxDC Survey | BCBS NC Survey |
| CareFirst BCBS | Employer must report:
|
Employer must report:
|
No survey is required. | |
| Cigna | Carrier will report. | Carrier will report. | No survey is required. | |
| Cigna + Oscar | Carrier will report. | N/A | No survey has been announced. | |
| Cigna Administered by Oscar | Carrier will report. | N/A | No survey has been announced. | |
| ConnectiCare | Carrier will report. | N/A | Details pending for 2024. | |
| EmblemHealth | Carrier will report. | Carrier will report. | Details pending for 2024. | EmblemHealth CAA page |
| Florida Blue | Carrier will report. Will require additional information from clients via survey. |
Carrier will report. Will require additional information from clients via survey. |
Complete survey questions by March 1st, 2024. Fully Insured Survey Administrative Services Only (ASO) Survey |
|
| Highmark | Highmark will report on behalf of all fully insured clients that complete the online survey by May 1, 2024. | Highmark will report on behalf of self-insured ASO clients that complete the online survey by the deadline May 1, 2024. Please note: ASO clients with carved-out pharmacy benefits will need to work with their PBMs to submit the data files specific to the pharmacy benefit (D3 - D8). This is the same approach that was followed for the calendar year 2022 submission. |
Fully insured clients and ASO clients that would like Highmark to submit premium data to CMS on their behalf must submit all of the required information to Highmark by no later than May 1, 2024 via the Prescription Drug Survey. Fully Insured Clients: All fully insured group health plan clients must submit the: (1) average monthly premium amounts paid by the employer (2) average monthly premium amounts paid by members in calendar year 2023 by no later than Wednesday, May 1, 2024, via the survey. Please note that the premium information collected will be reported on an aggregated basis – premium details will not be broken out by individual clients. Highmark will incorporate the premium information provided by fully insured clients into our aggregated reporting package. Self-Insured (ASO) Clients: ASO clients that would like Highmark to submit premium data to CMS on their behalf must submit all of the required information to Highmark by no later than Wednesday, May 1, 2024, via the survey. Please note that the premium information collected will be reported on an aggregated basis – premium details will not be broken out by individual clients. If the client does not complete the survey by the deadline, they will be responsible for the submission of the premium data file (D1) and corresponding plan file (P2) directly to CMS. Please note that ASO clients with carved-out pharmacy benefits will need to work with their PBMs to submit the data files specific to the pharmacy benefit (D3 - D8). This is the same approach that was followed for the calendar year 2022 submission. |
Client Email Process Overview Survey Worksheet CMS RxDC Homepage |
| Horizon BCBSNJ | Carrier will report. | Carrier will report. Will not collect external carrier files to aggregate data. Will not submit D3-D8 Pharmacy data files if Prime Therapeutics is not the designated PBM. |
No survey is required. | Horizon BCBSNJ CAA RxDC 2024 |
| Humana | Carrier will report. Will require additional information from clients via survey. |
Varies; refer to Humana's Prescription Drug Data Guide. | Will be sending health plan sponsors an online survey early February 2024. |
Humana Prescription Drug Data Guide |
| Independence Blue Cross (IBC) | IBC will report on behalf of all fully insured clients that complete the online survey by May 1, 2024. IBC/ Independence Administrators will submit all files including P2, D1, and D2-D8 on behalf of fully insured customers to CMS in one reporting package based on the data they currently have within their systems for the timeframes required for the reports. |
Carrier will report if the survey is completed online. IBC/ Independence Administrators will produce and submit files P2, D1, and D2 for self-funded customers based on the data they currently have within their systems for the timeframes required for the reports. Important Notes: If a self-funded customer has OptumRx as their PBM, OptumRx will provide files D3 through D8 to IBC/ Independence Administrators. For self-funded customers that carve out prescription drug benefits, data for files D3 through D8 will not be included. IBC/ Independence Administrators will submit all files to CMS in one reporting package. |
To obtain the employee contribution information, IBC/ Independence Administrators will be requesting the information via an online form (for all fully and self-insured groups), due May 1, 2024. Information collected will include: Yearly total employee contribution based on the type of product the customer offers (HMO or PPO). For self-funded customers who submit Form 5500, the Form 5500 plan number. For self-funded customers that carve out prescription drug benefits, the pharmacy benefit manager (PBM) name and EIN. |
IBC CAA RxDC 2024 IBC Prescription Drug Data Collection (RxDC) |
| Independence Administrators (IA) | N/A | Carrier will report. Will produce and submit files P2, D1 and D2, as a service to our self-funded customers, based on the data IA currently has within its systems for the timeframes required for the reports. If the self-funded client has Optum Rx as their PBM, Optum Rx will provide the files D3 through D8 to IA. IA will submit all files to CMS in one ‘reporting’ package. For self-funded customers with coverage through a different PBM, data for the D3 through D8 files will not be included. |
No survey is required. | IA RxDC 2024 |
| Oscar | Carrier will report. | N/A | No survey has been announced. | |
| UnitedHealthcare Oxford | Carrier will report for groups using OptumRx as PBM. Groups with other PBMs (including OptumRx Direct) should refer to the CAA UHC Approach to Pharmacy Benefits and Costs Reporting Guide. |
Carrier will report for groups using OptumRx as PBM. ASO groups and groups with other PBMs (including OptumRx Direct) should refer to the CAA UHC Approach to Pharmacy Benefits and Costs Reporting Guide. |
Any group that does not have a Surest or UMR policy will use the first UHC RFI link regardless of group segment or whether they are fully-insured vs. level-funded. The UMR link and Surest link are for large groups (51+) that have a UMR or Surest policy. The deadline for employers to complete the UHC or Surest RFIs is April 10, 2024. The deadline for employers to complete the UMR RFI is March 31, 2024 Additional resources: |
For further details, visit the CMS CAA Prescription Drug Reporting (RxDC) resources below.
- CMS Prescription Drug Data Collection Resource Page
- RxDC Reporting Instructions (PDF)
- RxDC Reporting Frequently Asked Questions (PDF)
