The Consolidated Appropriations Act (CAA) of 2021 introduced a host of compliance obligations for health plans and insurance issuers, all aimed at increasing “transparency” in health care. One of the most significant is the Rx Data Collection (RxDC) requirement, which requires that plans and issuers report prescription drug and health care spending for the 2024 calendar year by June 1, 2025. This is an ongoing annual requirement, with future deadlines continuing to fall on June 1st of each year.
Group plans and issuers must report:
- P2 – Plan information: Name, sponsors, and EINs, market segment, state, plan year, number of participants
- D1 – Gross premiums and employer/employee contributions
- D2 – Total health care spending
- D3 – Top 50 most-frequently dispensed brand-name drugs
- D4 – Top 50 most costly drugs
- D5 – Top 50 drugs by spending increase
- D6 – Prescription spending and utilization – by the plan and participants
- D7 – Prescription drug rebates, fees, etc.
- D8 – Prescription rebates for the top 25 drugs with the highest amount of rebates
For fully insured groups, insurance carriers are generally responsible for submitting RxDC reports on behalf of their employer clients. However, each carrier’s approach varies, and many require employer input (especially regarding employer/employee contribution data) via surveys or RFI’s before filing reports with the Centers for Medicare & Medicaid Services (CMS).
Employers that do not respond to these carrier requests may be required to file the complex P2 and D1 reports on their own, often necessitating legal counsel and coordination with their carrier. Self-funded employers typically bear the responsibility of compiling these reports in collaboration with their Administrative Services Only (ASO) provider, Pharmacy Benefit Manager (PBM), and legal counsel.
Brokers and employers looking for a deeper understanding of the CAA RxDC requirements, including compliance obligations and reporting details, should read our newsroom column: CAA Pharmacy Rx Data Collection (RxDC) Compliance Requirements due by 6/1.
The CMS has updated its RxDC Reporting Instructions Guide to assist plans and issuers with reporting, alongside additional resources available on the CAA RxDC website.
Aetna
- Will you be filing the D2 file for your fully insured clients?
- Yes
- Will you survey your group clients to verify employer contributions for the D1 filing?
- Deadline
- March 31, 2025
- What happens if an employer misses the deadline?
- Aetna will submit the report even if it’s missing the required data. Failure to respond will impact Aetna’s ability to accurately report on the clients behalf, and Aetna will not be responsible for any liability associated with the inaccurate report.
- The group can submit the data for average monthly premium directly to the CMS through their HIOS system.
- How can employers confirm their CAA RxDC files have been filed?
- Aetna will file by the required deadline of 6/1/25, however they will not provide confirmation.
- Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
- Brokers will not be cc’d on the emails to request information from their employer groups. The email includes a link to fill out the information that is specific to the plan sponsor.
Anthem Blue Cross (CA)
- Will you be filing the D2 file for your fully insured clients?
- Yes
- Will you survey your group clients to verify employer contributions for the D1 filing?
- Yes
- Deadline
- March 19, 2025
- What happens if an employer misses the deadline?
- Anthem will file without their reported information.
- What type of communication will you send to employers about this?
- Surveys will be sent to employers the week of 2/17/2025.
- How can employers confirm their CAA RxDC files have been filed?
- Emails will be sent to employers and a news article will be posted for broker once the filing has happened.
- Can employers access copies of their P2 and D1-D8 files once they have been filed?
- Every month the reports are posted to our Machine Readable Files webpage that employers can access.
- Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
Blue Shield of California
- Will you be filing the D2 file for your fully insured clients?
- Yes
- Will you survey your group clients to verify employer contributions for the D1 filing?
- Yes
- Groups or their brokers with access to an Employer Connection account are encouraged to complete the survey by logging in to Employer Connection.
- Groups or their brokers without access to an Employer Connection account can submit required information via the Prescription Drug & Healthcare Spending Survey using their group ID and following web key: #25yr24
- Yes
- Deadline
- April 19, 2025
- What happens if an employer misses the deadline?
- Groups that miss the deadline will not be included in Blue Shield’s filing and may be subject to non-compliance if they do not report the required data directly to the CMS on their own.
- What type of communication will you send to employers about this?
- Update 2/19/2025: Broker communications will go out today at 12 PM and employer communications will go out today at 4 PM.
- We will send a follow up email to groups that have not yet completed the survey, reminding them to complete the survey before the deadline.
- How can employers confirm their CAA RxDC files have been filed?
- Emails will be sent to employers and a news article will be posted for broker once the filing has happened.
- Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
CaliforniaChoice
Like last year, CalChoice is facilitating the RxDC for its employers and their plans for the 2024 Reference Year (Reporting Due June 1, 2025). There is no action required from the employer. CalChoice will coordinate directly with their carriers to facilitate all reporting obligations.
| Carrier | RxDC reporting plan for CHOICE Groups |
|---|---|
| Anthem | CHOICE is providing Anthem with the requested data report. No additional action is needed by CHOICE groups. |
| C+O | C+O did not request assistance from CHOICE. No additional action is needed by CHOICE groups. |
| Health Net | Health Net did not request assistance from CHOICE. No additional action is needed by CHOICE groups. |
| Kaiser Permanente | CHOICE is providing Kaiser Permanente with the requested data report. No additional action is needed by CHOICE groups. |
| Sharp Health Plan | CHOICE is providing Sharp with the requested data report. No additional action is needed by CHOICE groups. |
| Sutter Health Plan | CHOICE is providing Sutter with the requested data report. No additional action is needed by CHOICE groups. |
| United Healthcare | CHOICE is providing UHC with the requested data report. No additional action is needed by CHOICE groups. |
| Western Health Advantage | CHOICE is providing WHA with the requested data report. No additional action is needed by CHOICE groups. |
Cigna (NV)
- 2024 Reference Year (Reporting Due June 1, 2025):
- W&B is waiting for Cigna’s information.
HealthNet
- Will you be filing the D2 file for your fully insured clients?
- Yes
- Will you survey your group clients to verify employer contributions for the D1 filing?
- No – Health Net will not be requesting any data from the groups to complete plan list P2 and data file D1 on behalf of their clients. No employer action is required, and there are no associated deadlines for group clients.
- What type of communication will you send to employers about this?
- The plan will not be issuing any type if communications to the members/groups/brokers regarding RxDC filing (confirmation of filing completion, compliance with the reporting requirements, etc..)
- How can employers confirm their CAA RxDC files have been filed?
- Health Net will meet all regulatory obligations for 2024 reporting due on 06/01/2025.
- Can employers access copies of their P2 and D1-D8 files once they have been filed?
- No
- Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
- The group does not need to take any actions regarding the reporting or pay any fees to Health Net for the reporting.
Kaiser Permanente
- Will you be filing the D2 file for your fully insured clients?
- Yes
- Will you survey your group clients to verify employer contributions for the D1 filing?
- Yes – Fully insured employer groups will need to complete the RxDC survey form on KP’s employer portal
- Deadline
- March 31, 2025
- What happens if an employer misses the deadline?
- The group can submit the data for average monthly premium directly to the CMS through HIOS system.
- What type of communication will you send to employers about this?
- KP will send monthly newsletters from Marketing and the Broker Blast. There will be no additional email communication sent to contract signers outside of the monthly newsletters.
- How can employers confirm their CAA RxDC files have been filed?
- After the June 1 submission deadline, employer groups may reach out to their account manager to confirm the status of any RxDC reporting submission to CMS.
- Can employers access copies of their P2 and D1-D8 files once they have been filed?
- N/A
- Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
- How can employers and brokers with questions about your processes contact you for more information and support?
- N/A
Prominence Health (NV)
- Will you be filing the D2 file for your fully insured clients?
- Yes
- Will you survey your group clients to verify employer contributions for the D1 filing?
- Yes
- Deadline
- March 26, 2025
- What happens if an employer misses the deadline?
- TBD
- What type of communication will you send to employers about this?
- Starting the week of February 26th, we will send an email to all Fully Insured Large Group and Small Group clients. This email will include a link to an online form where you can easily provide the required premium information.
- How can employers confirm their CAA RxDC files have been filed?
- Prominence will notify clients via email and post an update on the Prominence Employer Portal bulletin board.
- Can employers access copies of their P2 and D1-D8 files once they have been filed?
- TBD
- Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
- TBD
- How can employers and brokers with questions about your processes contact you for more information and support?
- TBD
Sharp Health Plan
- Will you be filing the D2 file for your fully insured clients?
- Yes
- Will you survey your group clients to verify employer contributions for the D1 filing?
- Yes
- Deadline
- April 18th, 2025 (tentative)
- What happens if an employer misses the deadline?
- If employers fail to provide the information needed to file on their behalf, then the employer will need to file on their own.
- What type of communication will you send to employers about this?
- We plan to start outreach to employers on March 20th (tentative).
- How can employers confirm their CAA RxDC files have been filed?
- If they provide information by deadline, they will be included.
- Can employers access copies of their P2 and D1-D8 files once they have been filed?
- No, we will submit our filing with all employer information.
- Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
- TBD.
- How can employers and brokers with questions about your processes contact you for more information and support?
- They can contact their account managers.
United Health Care
- Will you be filing the D2 file for your fully insured clients?
- Yes
- Will you survey your group clients to verify employer contributions for the D1 filing?
- Yes – UHC will request employer contribution data via a Request for Information (RFI) survey.
- Deadline
- March 31, 2025
- What happens if an employer misses the deadline?
- If an employer does not complete the RFI, UHC will submit the data in their system to CMS by the June 1 deadline. However, the submission will be incomplete, and any missing data will need to be submitted directly by the employer.
- What type of communication will you send to employers about this?
- UHC will send reminders via their Connect electronic newsletter to customers, brokers, and consultants regarding the data collection process
- How can employers confirm their CAA RxDC files have been filed?
- Employers can check their submission status through the UHC RFI tool on the Employer & Broker portals
- Can employers access copies of their P2 and D1-D8 files once they have been filed?
- No, UHC does not provide copies of the submitted reports to employers
- Is there any other relevant CAA RxDC reporting information to share with your fully insured employers?
- How can employers and brokers with questions about your processes contact you for more information and support?
- TBD
Western Health Advantage
- Will you be filing the D2 file for your fully insured clients?
- Yes
- Will you survey your group clients to verify employer contributions for the D1 filing?
- Deadline
- April 15, 2025
- What type of communication will you send to employers about this?
- UHC will send reminders via their Connect electronic newsletter to customers, brokers, and consultants regarding the data collection process
- How can employers and brokers with questions about your processes contact you for more information and support?
- If you have any questions, please contact WHA’s Account Services at 888.499.3198.