The annual deadline for Prescription Drug Data Collection (RxDC) reporting is fast approaching. By June 1, 2025, all employer-sponsored group health plans, whether fully insured, self-funded, or level-funded, must submit detailed data on prescription drug and health care spending for the 2024 calendar year to the Centers for Medicare & Medicaid Services (CMS).
This reporting requirement, established under federal law, is intended to promote transparency around rising drug costs and health care spending trends. CMS uses the data to analyze cost drivers and the impact of rebates on premiums and out-of-pocket expenses.
What HR Teams Need to Know
RxDC reporting isn't just a compliance task for carriers or brokers. It directly affects HR departments, especially those managing employee health benefits. Whether you’re working with a traditional insurer or administering a self-funded plan, it’s essential to understand your role in the reporting process.
For Fully Insured Plans:
Most insurance carriers will handle RxDC submissions on behalf of their employer clients. However, it’s important for HR to confirm this arrangement is in place and in writing. If the insurer has agreed to report and fails to do so, the liability rests with the insurer, not the employer, as long as there’s a documented agreement.
For Self-Funded Plans: The responsibility is more complex. Even if a third party such as a TPA or pharmacy benefit manager (PBM) agrees to submit the report, the legal obligation remains with the plan sponsor: the employer. Self-funded employers must ensure reporting duties are clearly defined in vendor contracts and that all required plan-level data is submitted.
What’s Included in the RxDC Report?
The RxDC submission includes multiple files, some of which require detailed plan-specific information:
- Premiums and cost-sharing amounts
- Enrollment data
- Medical and pharmacy benefit structures
- Prescription drug spending, rebates, and utilization patterns
Employers may need to coordinate with multiple vendors (e.g., PBM and TPA) to ensure all components are submitted correctly.
Next Steps for HR
To stay on track:
- Confirm who is submitting the RxDC report for your plan(s)
- Review contracts with TPAs, PBMs, and insurers to ensure reporting responsibilities are clearly assigned
- Respond promptly to data requests from vendors involved in the submission
- Monitor CMS resources and reporting instructions for updates
Don’t assume reporting is automatic. Take steps now to ensure your plan is covered.
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This article is for informational purposes only and is not intended as legal, tax, or benefits advice. Readers should not rely on this information for taking (or not taking) any action relating to employment, compliance, or benefits. Always consult with a qualified professional before making decisions based on this content.
