Alerts

Overview

Employer-sponsored group health plans are subject to annual reporting of their plan's prescription drug spending, known as Prescription Drug Data Collection (RxDC) reporting. The requirement is intended to increase transparency around prescription drug and overall health care spending. Although insurers, third-party administrators (TPAs), and pharmacy benefit managers (PBMs) frequently assist with reporting, employer plan sponsors, particularly those with self-funded plans, are plan fiduciaries and retain important compliance responsibilities.

The next RxDC report is due June 1, 2026, covering data for the 2025 calendar year. (See the World Employee Benefits Compliance Calendar for additional upcoming plan deadlines.)

Carriers will often have relatively early timelines to obtain their information, so employers should seek the appropriate data from them as soon as possible. 

Plans Subject to RxDC Reporting

RxDC reporting applies to most group health plans (including grandfathered plans), whether they are fully insured or self-funded (including level-funded).*

Excepted Benefits - The requirement does not apply to excepted benefits (such as standalone dental or vision coverage) or account-based arrangements (such as standalone HRAs).

Fully Insured Plans

For fully insured plans, the insurance carrier typically submits RxDC data on behalf of the plan. When the carrier has agreed in writing to handle reporting, the carrier is responsible for compliance.

Self-Funded (including level-funded) Plans

For self-funded plans, vendors often take on responsibility for reporting. However, the legal obligation to comply remains with the employer, even when reporting is delegated to a TPA, PBM, or other vendor. Therefore, the employer should seek confirmation from the vendor, in writing, that the vendor is completing the filing. 

RxDC Reporting Instructions and Resources

CMS publishes detailed technical and operational guidance for RxDC reporting on its Prescription Drug Data Collection webpage. Employers will need to register if they are submitting the information directly (although doing so is likely beyond the capabilities of most employers). CMS provides instructions to understand file types, submission methods, and data standards. 

Official CMS RxDC Reporting Instructions can be found at:

CMS Prescription Drug Data Collection (RxDC)

The detailed technical information is quite complex. However, employers are not expected to prepare the technical files themselves, but familiarity with these resources can help support vendor oversight and confirmation of compliance. 

What If a TPA or Carrier Will Not File on the Plan's Behalf?

If a TPA, PBM, or carrier declines to submit RxDC data for a plan, employers should take immediate steps to address compliance risk—particularly for self-funded plans. 

• Determine whether the vendor is declining to submit all RxDC files or only specific components (for example, pharmacy versus medical data). 
• RxDC reporting may be split among multiple vendors. Employers may be able to rely on another vendor (such as a PBM or medical TPA) to submit certain files while coordinating remaining submissions separately.
• Engage a Reporting Vendor (if needed) - If the vendors will not submit their data, or only partially, employers should engage a third-party reporting service with RxDC expertise to assist with data coordination and submission.
• Submit Directly Only as a Last Resort - CMS allows employer-sponsored plans to submit RxDC files directly, but federal agencies have indicated this is expected to be uncommon due to technical complexity.
• Document Good-Faith Compliance Efforts - Employers should retain written records showing attempts to secure vendor reporting support, confirmations of vendors' positions, and alternative arrangements pursued. 

Consult Benefits Counsel or Compliance Advisors

Legal or compliance guidance can help employers assess regulatory exposure and determine appropriate corrective steps. 

Key Takeaways for Employers

• RxDC reporting is an annual obligation of group medical plans (other than excepted benefit plans). 
• Fully insured plans can likely rely on the carriers, but should obtain that assurance in writing. 
• Self-funded (including level-funded) plan sponsors remain legally accountable but can delegate the obligation to vendors to complete on their behalf. 
• Early vendor confirmation and contingency planning are essential.