Update: Prescription Drug Data Collection (RxDC) Reporting

Under the Consolidated Appropriations Act, 2021 (CAA), health issuers offering group or individual health coverage and self-funded group health plans must submit detailed data on prescription drug pricing and healthcare spending. This data submission is called the Prescription Drug Data Collection (RxDC) Report.

The first RxDC report was due December 27, 2022 (for reference years 2020 and 2021), with subsequent reporting due annually by June 1. Required entities must submit the report through a web portal managed by the Centers for Medicare & Medicaid Services (CMS). This data is collected on behalf of the Departments of Health and Human Services, the Department of Labor, and the Department of the Treasury.

The reporting requirements include information intended to do the following:

• Show the significant drivers of prescription drug and healthcare costs increases
• Improve understanding of how prescription drug rebates impact premiums and out-of-pocket costs
• Enhance prescription drug pricing transparency

The Premera approach

As with the initial reporting, Premera will submit the reference year 2024 report, which is due by June 1, 2025. The report will include plan lists P1-P2, data files D1-D8, and the required narrative response.

To gather additional data needed for reporting this year, Premera will be implementing a survey for groups to fill out. The survey link will be located on the employer page of the Premera website. The survey will be available beginning March 1, 2025, for a total duration of 9 weeks to allow ample time for submissions. All responses are due by 12 p.m. Pacific Time on April 25, 2025.

Groups with pharmacy carved out

Employer groups that have pharmacy benefits carved out should coordinate with other carriers to ensure they report all required information. (Pharmacy benefits carve-outs occur when pharmacy benefits are separated from medical benefits and managed outside of their organization’s primary medical health plan.)

As with last year’s reporting, Premera will continue to report the following on behalf of groups for reference year 2024 by the June 1, 2025 deadline.

• • P2-Group health plan list
  • D1-Premium and life years
  • D2-Spending by category
  • Narrative response

Groups who do not want Premera to report on their behalf must contact their Premera Representative no later than March 15, 2025, to ensure the group is excluded from Premera’s aggregate reporting.

Employer groups reporting independently must submit a request for any Premera data required for their submission no later than April 1, 2025.

Please contact your Premera representative or producer if you have questions about this requirement.