RxDC Is Due June 1. If Your Carrier Sent a Request, Answer It.
The prescription drug data collection report is one of the few filings where a fully insured employer can still be the reason it is late. Steven Hinton on what the carrier is asking for and why the email is not spam.
Every spring a few of our clients forward me an email from their carrier with the subject line "Action required: RxDC data request," and ask if it is legitimate. It is. Here is what it is for and what to do with it.
What RxDC is
The Consolidated Appropriations Act requires every group health plan to report prescription drug and health care spending data to the federal government each year. The report for the 2025 reference year is due June 1, 2026. The data gets aggregated and published to show where drug spending is going.
Who actually files it
If you are fully insured, your carrier files the bulk of the report. But a few data points live with you, not them: your average monthly premium, how much of that premium employees paid versus the employer, and sometimes your headcount by state. The carrier cannot file without those numbers, so they send a request, usually in April or May with a deadline a few weeks before June 1.
If you are self-funded, it is split. Your TPA files the medical pieces, your PBM files the pharmacy pieces, and somebody has to file the plan-level information. Confirm in writing who is doing what, because the plan is responsible for all of it even though three different vendors are touching it.
What happens if you ignore the request
The carrier files what it can and flags the plan as incomplete, or in some cases files nothing for your group. Either way the compliance gap belongs to the employer, not the carrier. The request takes about fifteen minutes to complete if you have your payroll deduction schedule handy. It is not worth the risk to let it sit.
Two things that help
Keep a simple spreadsheet of monthly premium and employee contribution by tier for every plan year. You will need it for RxDC, for the 1095-C affordability line, and for the Form 5500 if you file one. And add the RxDC request to your compliance calendar as an April item so you are looking for the email rather than being surprised by it.
If you got a request and are not sure which numbers they want, forward it to us. We can usually fill it in from the renewal file.
This article is for general informational and educational purposes only and does not constitute insurance, legal, tax, or financial advice. For guidance specific to your organization, talk with an FBP advisor.
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