Each year, group health plans must report detailed prescription drug and healthcare spending data to the Centers for Medicare & Medicaid Services (CMS). This reporting—commonly referred to as RxDC reporting—is due by June 1 and applies to most employer-sponsored group health plans that offer prescription drug coverage.

Reporting is based on the prior calendar year, regardless of the plan’s renewal date or plan year. For example, the June 1, 2026 deadline reflects data from the 2025 calendar year.

What Is RxDC Reporting?

RxDC reporting was established under the Consolidated Appropriations Act, 2021 and is intended to increase transparency around prescription drug costs and overall healthcare spending. The submission includes information about premiums, claims, prescription drug spending, and enrollment.

Because the required data comes from multiple sources, different vendors are often responsible for separate portions of the reporting. In many cases, vendors submit data on an aggregated basis across multiple clients rather than on a plan-specific level.

RxDC reporting generally does not apply to excepted benefits such as stand-alone dental or vision coverage.

Who Is Responsible?

Although insurance carriers, TPAs, and pharmacy benefit managers (PBMs) frequently assist with the reporting process, the legal responsibility generally rests with the group health plan sponsor.

In practice, responsibilities vary by arrangement, and more than one party may be involved.

For fully insured plans, carriers often submit most or all required data, but employers may still need to provide supplemental information. For self-funded plans, TPAs and PBMs typically handle reporting components, but employers must confirm who is submitting each required file.

Employers should not assume that a single vendor is handling the entire submission.

Why Employers Are Being Contacted

Even when vendors are handling portions of the reporting, employers are often contacted for plan-specific information needed to complete the submission—particularly for plan-level data.

These requests may include employer and employee contribution amounts, average monthly premium information, enrollment counts or validation, and plan or vendor identification details.

These requests are a normal and necessary part of the reporting process.

What Employers Should Do Now

To stay on track, employers should take a proactive approach. Employers should review and respond promptly to all RxDC-related communications from carriers, TPAs, and PBMs, and pay close attention to vendor-specific deadlines, which often occur before June 1.

Employers should also confirm which vendor is responsible for each portion of the reporting and ensure all plan vendors, including prior vendors if applicable, are accounted for in the reporting year. It is also important to retain documentation showing how the reporting obligation was satisfied.

Failure to respond to vendor data requests in a timely manner may result in the vendor declining to include the plan in its filing, potentially leaving the employer responsible for submitting certain components directly.

Final Reminder

Even when vendors are handling the reporting, employers should take a moment to confirm that the process is complete and on track. A brief review now can help avoid last-minute questions or gaps as the June 1 deadline approaches.

Although detailed enforcement guidance remains limited, RxDC reporting is a required federal obligation, and employers should treat it accordingly.

If you have questions about RxDC reporting or need assistance coordinating with your vendors, your INSURICA team is available to help.

This is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel or an insurance professional for appropriate advice.