Reminder: RxDC Reporting Due June 1st

As a reminder, the Consolidated Appropriations Act, 2021 includes a provision that requires group health plans and health insurance issuers (collectively “plans and issuers”) to report certain specified data related to prescription drug and other health care spending. The first RxDC report (for 2020 and 2021) was due on January 31, 2023, with the reports for 2022 and 2023 due on June 1, 2023 and June 1, 2024, respectively. The deadline to submit reporting for calendar year 2024 is June 1, 2025 (and continues each June 1^st thereafter).

Next Steps for Employers

In anticipation of the June 1, 2025 deadline, plan sponsors may receive communications from their carriers, TPAs, PBMs and other vendors regarding their expectations for completing the reporting. In our experience, carriers, TPAs, PBMs, and other vendors have varying requirements and expectations of what they need from plan sponsors to successfully complete the reporting, and some may delegate some of the reporting responsibility to the plan sponsor. For example, if your insurance company, TPA, or PBM sent you a survey or questionnaire to collect information about plan numbers, premium, or funding types, it is likely that they are reporting the P2 and D1 files on your behalf. Therefore, we recommend the following:

• Respond to any requests for information you may receive and coordinate with your vendors to understand their expectations to ensure all reporting is completed in full on behalf of the plan. 
  Note: Some carriers require responses by early March.
• If your vendor sent you an email or letter asking you to create a HIOS account or stating that they will not submit P2 and D1 on your behalf, that means you must submit P2 and D1 directly to CMS (or engage a third-party to submit them for you). Thus, you and/or a third party submitting P2 or D1 on your behalf will need to follow the RxDC Reporting Instructions and timely complete the submission.

About the Author 

This alert was prepared for Woodruff Sawyer by Barrow Weatherhead Lent LLP, a national law firm with recognized experts on ERISA, Affordable Care Act. Contact Stacy Barrow or Nicole Quinn-Gato at sbarrow@marbarlaw.com or nquinngato@marbarlaw.com.

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