Prescription Drugs

RxDC Reporting Deadline Reminder

03/29/2024 Written by: Tom Seltz

As we mentioned in a recent blog article, it’s officially time for employers with prescription drug coverage to prepare for 'round 3' of the now annual Prescription Drug Data Collection (RxDC) Reporting (also known as “CAA §204 Reporting”). As a reminder, RxDC Reporting is required for all group health plans that include prescription drug coverage, regardless of size. It does not apply to FSAs, HRAs, or retiree-only plans.

RxDC Reporting collects information on prescription drug and health care spending, including:

  • General information regarding the plan or coverage
  • Enrollment and premium information, including premiums paid by employees versus employers
  • Total health care spending, broken down by type of cost (hospital care; primary care; specialty care; prescription drugs; and other medical costs), including prescription drug spending by enrollees versus employers and carriers
  • The 50 most frequently dispensed brand prescription drugs
  • The 50 costliest prescription drugs by total annual spending
  • The 50 prescription drugs with the greatest increase in plan expenditures from the previous year
  • Prescription drug rebates, fees, and other remuneration paid by drug manufacturers to the plan or carrier in each therapeutic class of drugs, as well as for the 25 drugs that yielded the highest amount of rebates
  • The impact of prescription drug rebates, fees, and other remuneration on premiums and out-of-pocket costs

Detailed reporting instructions, including templates for the various data files and other important information, can be found on the CMS RxDC website. However, we wanted to follow up on our previous overview and remind everyone that certain deadlines may vary from insurer to insurer or TPA to TPA, or even PBM to PBM. Although the statutory deadline for RxDC Reporting for the 2023 calendar year is June 1, 2024, most insurers, TPAs, and PBMs are willing to file on the plan sponsor’s behalf if their internal process is followed and certain deadlines are met. Please check with your insurer/TPA/PDM for their specific deadlines. For example, internal deadlines differ for UnitedHealthcare (April 10th) as they do for Aetna (April 12th), and so on and so forth. Please be mindful of this as the deadlines are rapidly approaching.

While the deadlines mentioned above are certainly not an exhaustive list, it should be noted that other deadlines may apply depending on your exact situation. For example, plans that carved out Rx coverage through a third-party PBM during 2023 may have additional responsibilities (or help), dependent upon the PBM's particular approach.

Employers and plan sponsors who miss their carrier’s or TPA’s/PBM’s deadlines must complete RxDC Reporting themselves by June 1 or hire a vendor. Please contact your AssuredPartners Account Management Team for details or vendor introductions/quotes.

Finally, please note that while they sound similar, the RxDC Reporting requirement is unrelated to the CMS Online Disclosure Form, which is a quick and painless online form that all health plans with Rx coverage must submit to CMS within 60 days of the start of each new plan year. It is also unrelated to the Gag Clause Prohibition Compliance Attestations due each December 31st, and which are also submitted to CMS.

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