Prescription Drug Data Collection (RxDC) Reporting
CAA 2021 § 204; ERISA § 725; PHS Act § 2799A-10
Plans and issuers must report prescription drug and health care spending data to CMS. Includes top 50 brand drugs by spend, top 50 most utilized generics, Rx rebate data, premium and cost-sharing trends, and total spending by category. For fully insured plans, the carrier typically reports the bundled data to HIOS; the plan sponsor may need to provide its share of premium data to the carrier for inclusion.
Current Fee / Rate Information
No filing fee. Annual submission to CMS by June 1. Covers prior calendar year. Plans, issuers, and PBMs may coordinate reporting responsibilities.
Last reviewed: July 2026
Non-Compliance Penalties
Failure to report: $100/day per affected individual under ERISA § 502(c)(10). CMS enforcement is evolving.
What is RxDC reporting?
RxDC stands for prescription drug data collection. Every year, group health plans report their drug and healthcare spending data to CMS: the top 50 brand drugs by spend, the top 50 most-dispensed generics, rebate totals, premiums, and cost-sharing trends. The submission covers the prior calendar year and is due June 1.
Who actually files it?
Almost never the employer alone. The submission splits into files (D1 through D8 plus a narrative), and different vendors own different pieces. Your PBM typically files the drug data files. Your carrier or TPA files the spending files. But the premium file (D1) often needs numbers only you have: your premium split between employer and employee. The plan sponsor stays legally responsible even when vendors do the filing.
What to do each spring
- By March: ask your carrier, TPA, and PBM in writing which RxDC files each one submits for you.
- Respond fast when they request your average monthly premium data. Miss their internal deadline and your data gets left out.
- By mid-June: get written confirmation that the submission went in through HIOS.
The most common failure isn't refusing to file. It's three vendors each assuming another one covered a file. Ask the question every year. Simple. No gaps.
Official Source
https://www.cms.gov/marketplace/about/oversight/other-insurance-protections/prescription-drug-and-health-care-spendingRelated Reading
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