Under the Consolidated Appropriations Act, 2021 (CAA), employer-based health plans are required to produce and file an annual report on their prescription drug and healthcare spending costs. The Centers for Medicare and Medicaid Services (CMS) is the collection agency for this information and the data submission is called the RxDC report. The Rx stands for prescription drug and the DC stands for data collection.

    Carriers and TPAs filed the initial reporting for calendar years 2020 and 2021 because the government issued relief stating information on premiums paid by employers and premiums paid by members was not required for those years. However, no such relief has been issued for the 2022 reporting. Employers are now required to prepare and submit this information or work with a vendor to complete this submission. This year’s RxDC report is due by June 1, 2023, covering data for 2022.

    While the CMS is the collection agency for this reporting data, enforcement for compliance falls upon the Department of Labor and U.S. Department of Health and Human Services. Non-compliance penalties of $100/day may be issued for health plans that do not comply with the RxDC reporting requirements.

    For more information on RxDC reporting, please refer to the CMS website: https://www.cms.gov/cciio/programs-and-initiatives/other-insurance-protections/prescription-drug-data-collection.

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