If you manage a group health plan, you have likely heard of RxDC reporting (which stands for Rx and Drug Collection).
Passed under the Consolidated Appropriations Act of 2021, this federal mandate requires group health plans to submit spending and prescription drug data to the Centers for Medicare & Medicaid Services (CMS) every year. The goal is to create transparency around rising healthcare and prescription drug costs.
While "federal reporting" can sound intimidating, the process is streamlined for you. Here is a quick, jargon-free guide on what to expect, who does the heavy lifting, and what small piece of data we will need from you.
Who Actually Files the Report?
Because compiling massive amounts of healthcare claim data is incredibly technical, you do not have to do this alone.
As a self-funded plan sponsor, the filing is handled on your behalf through a collaborative effort:
- Our Team (Your TPA): We handle the bulk of your medical claim and plan-level data.
- Your Pharmacy Benefit Manager (PBM): Your PBM handles the deep-dive prescription drug pricing, pharmacy claims, and drug distribution data.
Together, we submit these components directly to CMS. However, because we are filing on your behalf, we rely on you for a few specific financial data points that we do not have access to in our daily claims processing.
What We Need From You (And Why)
Every year, we will reach out to collect your group’s premium and enrollment data (often referred to as the D1 data file).
Because we process claims rather than run your payroll, we do not know how you divide the costs of your healthcare plan. Specifically, we will ask you to provide:
- Total Employee-Paid Premiums: The total dollar amount your active employees contributed toward their health coverage over the prior calendar year.
- Total Employer-Paid Premiums: The total portion your company paid toward the premiums.
- COBRA Member Data: Premium contributions paid by any COBRA participants.
Important Note: When calculating these numbers, you must include COBRA participants in your total counts and premiums. They are covered members under your plan and must be represented in the enrollment and premium totals.
The Annual Timeline
RxDC reporting is an annual cycle based on the previous calendar year's data. Here is what the yearly timeline looks like:
Data Request Sent
Early Spring
We will reach out to you with a simple, secure intake form or survey to collect your employee/employer premium splits and COBRA details for the prior calendar year.
Your Submission Deadline
Mid-Spring
We will ask you to return your completed financial details. Getting this back early is critical, as our system needs time to aggregate your numbers with the medical data before final filing.
Federal Filing Deadline
June 1
This is the hard federal deadline set by CMS. Our team and your PBM upload and submit the final, compiled reports to the government portal.
What happens if you miss our data request?
If we do not receive your premium data by our internal spring deadline, we cannot submit the report on your behalf. In that scenario, your company would be required to create an account with CMS and manually upload your own filing files to avoid compliance penalties.
The bottom line: Keep an eye out for our email in the spring, fill out the quick premium questionnaire, and we will take care of the rest!