What Is RxDC Reporting?
Prescription Drug Data Collection (RxDC) reporting is an annual requirement under the federal Consolidated Appropriations Act of 2021 (CAA). Each year, health plans and insurance carriers report prescription drug costs and overall health care spending to the Centers for Medicare & Medicaid Services (CMS).
The federal government uses the data to better understand:
- Prescription drug spending trends
- Rebates and fees paid to pharmacy benefit managers (PBMs)
- How prescription drug costs affect overall health care spending and premiums
Which Plans Report
RxDC reporting applies to group medical plans of all sizes – fully insured, self-funded and level-funded. It doesn’t apply to standalone dental and vision plans, Health Reimbursement Arrangements (HRAs), health Flexible Spending Accounts (FSAs) or retiree-only plans. Individual market plans also report, but this page focuses on employer plans.
Deadline
RxDC reports are due by June 1 each year and cover the prior calendar year, called the “reference year,” regardless of the plan year. For example, the report covering calendar year 2026 is due by June 1, 2027.
Fully Insured Plans
The carrier files the RxDC report, since it has the premium and claims data. The one piece carriers don’t always have is how the employer actually splits the premium with employees, since what’s written on the group application doesn’t always match the contribution strategy the employer uses in practice.
Carriers handle this differently. Many send employers a survey early in the year to confirm contributions, some capture it at renewal, and others report what’s on the application. When a carrier sends a survey, the employer’s response is what allows the carrier to report the plan accurately. If a survey is missed, the carrier generally places responsibility for reporting that information back on the employer.
Each year, Word & Brown posts a carrier roundup in the Education Resources Newsroom showing how each carrier partner captures and reports the employer contribution split. It includes links to carrier surveys if applicable, and what each carrier advises if a survey is missed.
Self-Funded and Level-Funded Plans
The plan itself is responsible for reporting. In practice, the employer’s PBM, third-party administrator (TPA) or administrative services only (ASO) partner usually submits the files for the parts of the plan it handles. CMS considers a report complete once it has all the required files, no matter who submits them. Employers filing any files on their own submit through CMS’s Health Insurance Oversight System (HIOS), and setting up an account can take time.
What’s Reported
The report is made up of a plan file and eight data files:
- P2 – Group health plan list: a list of every employer plan included in the report, with each employer’s name and EIN, the plan year and the number of covered members as of December 31. For fully insured plans, the carrier’s P2 file lists all the employer groups whose data is combined in its report.
- D1 – Premium and life-years: total premiums, broken out by what employers paid and what employees paid – the employer contribution split. It also reports life-years, a measure of how many people were covered over the year. This is the file most carrier surveys are about. For self-funded plans, premium equivalents are reported instead of premiums.
- D2 – Spending by category: total health care spending, broken out into categories such as hospital, primary care, specialty care, prescription drugs and other medical costs, including wellness.
- D3 to D5 – Top 50 drug lists: the 50 most frequently dispensed brand drugs, the 50 most costly drugs, and the 50 drugs with the biggest increase in spending from the prior year.
- D6 – Prescription drug totals: overall prescription drug spending and use, including how much the plan paid and how much members paid out of pocket.
- D7 and D8 – Rebates and fees: rebates, fees and other payments from drug manufacturers and PBMs, reported by drug class (D7) and for the 25 drugs with the highest rebates (D8).
Plans may also add optional narrative explanations. For fully insured plans, carriers report this data in aggregate across their employer groups.
Enforcement
The Departments of Labor, Health and Human Services, and the Treasury enforce RxDC reporting. Plans that don’t report may face penalties, including an IRS excise tax of up to $100 per day per affected individual.
Where Group Health Insurance Agents Fit
Brokers aren’t responsible for RxDC filings, and responding to the carrier survey is the employer’s responsibility. Brokers often act as stewards here. They know which carriers send surveys, point employers to them and remind them to watch for one, so the carrier can complete the report and the employer doesn’t have to file anything itself. Carriers that use surveys typically send several rounds of outreach before their deadline. Self-funded employers generally get RxDC support in partnership with their PBM, TPA, ASO partner or legal counsel.
Important: This information is provided for general educational purposes and reflects the rules as of November 2026. It is not legal or tax advice. How these rules apply depends on each employer’s specific circumstances, so employers should review their situation with their own legal counsel, ERISA attorney, CPA or tax advisor.