Group health plans and health insurance issuers must annually submit detailed information on prescription drug and health care spending to the Centers for Medicare and Medicaid Services (CMS). This reporting is referred to as the prescription drug data collection (RxDC report). The next RxDC report is due by June 1, 2026, covering data for 2025.
Most employers contract with third parties, such as issuers, third-party administrators (TPAs), and pharmacy benefit managers (PBMs), to submit RxDC reports on behalf of their health plans. Employers may work with multiple third parties to complete the RxDC report for their health plans. A health plan’s submission is considered complete if CMS receives all required files, regardless of who submits them.
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. However, the RxDC reporting liability stays with a self-insured health plan, even if a third party contractually agrees to submit the required information.
Employers should start reaching out to their issuers, TPAs, or PBMs, as applicable, to confirm that they will submit the RxDC files for their health plans by June 1, 2026. Employers should also confirm that their written agreements with these third parties address this reporting responsibility.
Also, employers will likely need to provide their third-party vendors with plan-specific information, such as enrollment and premium data, to complete their RxDC submission. Employers should watch for these vendor surveys and promptly provide the requested information.
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