The Consolidated Appropriations Act, 2021 (CAA) requires health plan sponsors to submit detailed information on prescription drug expenses and coverage reports to CMS annually by June 1st.
Published: 03.18.2026
| CARRIER | REPORTING FULLY-INSURED |
REPORTING SELF/LEVEL-FUNDED |
EMPLOYER SURVEYS | RESOURCES |
|---|---|---|---|---|
| Aetna | Aetna is committed to complying with all legal and regulatory requirements affecting their business operations and customer's health benefits. The following is how Aetna is helping their Small Group plan sponsors submit these reports. The submission process
We will submit the report without the required plan sponsor data. Failure to respond will impact our ability to accurately report on the plan sponsor’s behalf, and Aetna will not be responsible for any liability associated with the inaccurate report. What you can do: Help your clients gather and report the data so they won’t have anything else to worry about. Aetna RxDC Reporting Full Release |
Aetna is committed to complying with all legal and regulatory requirements affecting their business operations and customer's health benefits. The following is how Aetna is helping their Small Group plan sponsors submit these reports. The submission process
We will submit the report without the required plan sponsor data. Failure to respond will impact our ability to accurately report on the plan sponsor’s behalf, and Aetna will not be responsible for any liability associated with the inaccurate report. What you can do: Help your clients gather and report the data so they won’t have anything else to worry about. Aetna RxDC Reporting Full Release |
Starting February 2nd, Aetna will send an email to all Small Group plan sponsors with instructions on how to submit the required data. Clients should fill out the RxDC Plan Sponsor Data Collection Form with the required data by 3/31/2026. Required data:
|
Broker Submission Option: you may use this form to provide the information to Aetna on behalf of your client Aetna RxDC Reporting Full Release |
| AmeriHealth NJ |
For the June 1, 2026 Section 204 RxDC submission to the Centers for Medicare & Medicaid Services (CMS), AmeriHealth and AmeriHealth Administrators will report the actual premium amounts paid by the employer versus the actual premium amounts paid by members in 2025. Please note: Both fully insured and self-funded customers must submit their data through our online form by May 1, 2026. The form collects:
AmeriHealth and AmeriHealth Administrators will produce and submit files P2, D1, and D2 for both fully insured and self-funded customers based on the data they currently have within our systems for the timeframes required for the reports. If a self-funded customer has OptumRx as its PBM, OptumRx will provide files D3 through D8 to AmeriHealth and AmeriHealth Administrators. AmeriHealth will submit all files on behalf of fully insured customers. AmeriHealth and AmeriHealth Administrators will submit the files to CMS in one reporting package. For self‑funded customers who carve out prescription drug benefits, data for files D3 through D8 will not be included in our submission. In addition, we will be sending this information to customers via email. We are sharing this with you for awareness only. Please note that if a customer does not provide us with the requested data by May 1, AmeriHealth and AmeriHealth Administrators will submit the report to CMS without the customer’s data. Failure to respond with complete and correct information will impact our ability to report accurately on the customer’s behalf. AmeriHealth and AmeriHealth Administrators will not be responsible for any liability associated with an inaccurate report. It may be necessary for the customer to submit this information to CMS directly after May 1. |
For the June 1, 2026 Section 204 RxDC submission to the Centers for Medicare & Medicaid Services (CMS), AmeriHealth and AmeriHealth Administrators will report the actual premium amounts paid by the employer versus the actual premium amounts paid by members in 2025. Please note: Both fully insured and self-funded customers must submit their data through our online form by May 1, 2026. The form collects:
AmeriHealth and AmeriHealth Administrators will produce and submit files P2, D1, and D2 for both fully insured and self-funded customers based on the data they currently have within our systems for the timeframes required for the reports. If a self-funded customer has OptumRx as its PBM, OptumRx will provide files D3 through D8 to AmeriHealth and AmeriHealth Administrators. AmeriHealth will submit all files on behalf of fully insured customers. AmeriHealth and AmeriHealth Administrators will submit the files to CMS in one reporting package. For self‑funded customers who carve out prescription drug benefits, data for files D3 through D8 will not be included in our submission. In addition, we will be sending this information to customers via email. We are sharing this with you for awareness only. Please note that if a customer does not provide us with the requested data by May 1, AmeriHealth and AmeriHealth Administrators will submit the report to CMS without the customer’s data. Failure to respond with complete and correct information will impact our ability to report accurately on the customer’s behalf. AmeriHealth and AmeriHealth Administrators will not be responsible for any liability associated with an inaccurate report. It may be necessary for the customer to submit this information to CMS directly after May 1. |
Both fully insured and self-funded customers must submit their data through our online form by May 1, 2026. | |
| Anthem (CT, NY) | The Prescription Drug Data Collection reporting provision of the Consolidated Appropriations Act (CAA) requires reports on drug utilization and spending trends be submitted to the U.S. Department of Health and Human Services. As a reminder, we are required to include information in the average monthly premium paid by member and by employer in the Premium and Life Years (D1) reporting. To make sure your data is included in our aggregate filing for calendar year 2025 data, please complete this form before March 25, 2026. We must receive this data for you and us to avoid non-compliance. |
The Prescription Drug Data Collection reporting provision of the Consolidated Appropriations Act (CAA) requires reports on drug utilization and spending trends be submitted to the U.S. Department of Health and Human Services. As a reminder, we are required to include information in the average monthly premium paid by member and by employer in the Premium and Life Years (D1) reporting. To make sure your data is included in our aggregate filing for calendar year 2025 data, please complete this form before March 25, 2026. We must receive this data for you and us to avoid non-compliance. |
To make sure your data is included in our aggregate filing for calendar year 2025 data, please complete this form before March 25, 2026. We must receive this data for you and us to avoid non-compliance. | |
| BCBS of North Carolina (Blue Cross NC) |
Pending Carrier Response | |||
| CareFirst BCBS | Pending Carrier Response | . | ||
| Cigna | Pending Carrier Response | |||
| Cigna + Oscar | Pending Carrier Response | |||
| Cigna Administered by Oscar | Pending Carrier Response | |||
| ConnectiCare | Pending Carrier Response | |||
| EmblemHealth | Pending Carrier Response | |||
| Florida Blue | For the 2026 reporting phase, Florida Blue will collect necessary data from our employer groups through an external survey vendor (Qualtrics). The survey will launch on February 3, 2026, and we require a response from the groups by March 15, 2026. This effort demonstrates our continued commitment to meeting the CAA Section 204 reporting requirements. All collected data will be submitted to CMS by June 1, 2026, ensuring timely federal compliance for the current filing year. Details On February 3, 2026, our Section 204 data collection survey will go live for employer groups to complete. Our fully insured, MPP, and self-funded employer groups will receive an email or mailed letter from Florida Blue, detailing the specific data they need to provide through the survey to ensure compliance with federal filing: Fully Insured Employer Groups
Please note: Florida Blue will report all the survey data as an aggregate for Fully Insured or Self-Insured groups. If an employer group does not respond to our survey request, their data cannot be reported to CMS by Florida Blue. |
For the 2026 reporting phase, Florida Blue will collect necessary data from our employer groups through an external survey vendor (Qualtrics). The survey will launch on February 3, 2026, and we require a response from the groups by March 15, 2026. This effort demonstrates our continued commitment to meeting the CAA Section 204 reporting requirements. All collected data will be submitted to CMS by June 1, 2026, ensuring timely federal compliance for the current filing year. Details On February 3, 2026, our Section 204 data collection survey will go live for employer groups to complete. Our fully insured, MPP, and self-funded employer groups will receive an email or mailed letter from Florida Blue, detailing the specific data they need to provide through the survey to ensure compliance with federal filing: Self- Funded Employer Groups that DO NOT have Pharmacy Carveout
|
Florida Blue Full RxDC Release | |
| Highmark | Section 204 of the Consolidated Appropriations Act (CAA) of 2021 mandates that data be submitted to the Centers for Medicare & Medicaid Services (CMS) regarding prescription drug spending, healthcare spending, and enrollment for the 2025 calendar year. Highmark will submit the data on behalf of its fully insured and self-funded employer group clients in compliance with this year’s deadline. We need your help to collect the necessary premium information for our mutual clients. What do I need to know? Deadline: The deadline to submit the required information is April 17, 2026, at 11:59 PM EST. Late submissions will not be accepted. Data Required: We need specific premium data for both fully insured and self-insured (ASO) clients. The exact data required differs slightly between these groups (detailed below). This data will be aggregated and reported to CMS; individual client details will not be disclosed.
Survey Link: Direct your clients to complete the Highmark RxDC survey by clicking here . If clients need assistance, we've created the Section 204 Reporting - Highmark Client Tip Sheet 2026. What do I need to do? To ensure a high response rate for the RxDC survey, Highmark will contact clients stressing the April 17th deadline. Producers may be asked provide support as necessary. |
Section 204 of the Consolidated Appropriations Act (CAA) of 2021 mandates that data be submitted to the Centers for Medicare & Medicaid Services (CMS) regarding prescription drug spending, healthcare spending, and enrollment for the 2025 calendar year. Highmark will submit the data on behalf of its fully insured and self-funded employer group clients in compliance with this year’s deadline. We need your help to collect the necessary premium information for our mutual clients. What do I need to know? Deadline: The deadline to submit the required information is April 17, 2026, at 11:59 PM EST. Late submissions will not be accepted. Data Required: We need specific premium data for both fully insured and self-insured (ASO) clients. The exact data required differs slightly between these groups (detailed below). This data will be aggregated and reported to CMS; individual client details will not be disclosed.
Survey Link: Direct your clients to complete the Highmark RxDC survey by clicking here . If clients need assistance, we've created the Section 204 Reporting - Highmark Client Tip Sheet 2026. What do I need to do? To ensure a high response rate for the RxDC survey, Highmark will contact clients stressing the April 17th deadline. Producers may be asked provide support as necessary. |
Direct your clients to complete the Highmark RxDC survey by clicking here. | Section 204 Reporting - Highmark Client Tip Sheet 2026 |
| Horizon BCBSNJ | Under Section 204 of the Consolidated Appropriations Act, 2021 (CAA), insurance companies and employer-based health plans are required to submit information about prescription drugs and health care spending to the Centers for Medicare & Medicaid Services (CMS). This data submission is called the RxDC (prescription drug data collection) report. This information must be submitted to CMS by June 1, 2026, for 2025 data, and every year going forward, through a web portal set up by CMS. How this applies to Fully Insured Groups (including Level-Funded Plans) Horizon’s approach to CAA RxDC for fully insured groups (including Level-Funded plans) with active prescription drug coverage in 2025 will be consistent with our approach for the reporting years of 2020, 2021, 2022, 2023 and 2024 submitted to CMS. For Fully Insured Groups, Horizon will:
Horizon has determined that there is sufficient internally captured data regarding the number of members in an insured plan, the life year’s calculation, premiums paid, rates, contributions, etc. to produce information for the D1 columns. How this applies to Self-Insured Group Plans Horizon’s approach to CAA RxDC for self-insured groups with active prescription drug coverage in 2025 will be consistent with our approach for the June 1, 2025 submission of 2024 data to CMS. Self-insured plans will have to continue to submit the:
Going forward, Horizon will review any additional clarification and guidance to ensure compliance with the RxDC requirements and will update their approach, if needed for future submissions. |
Under Section 204 of the Consolidated Appropriations Act, 2021 (CAA), insurance companies and employer-based health plans are required to submit information about prescription drugs and health care spending to the Centers for Medicare & Medicaid Services (CMS). This data submission is called the RxDC (prescription drug data collection) report. This information must be submitted to CMS by June 1, 2026, for 2025 data, and every year going forward, through a web portal set up by CMS. How this applies to Fully Insured Groups (including Level-Funded Plans) Horizon’s approach to CAA RxDC for fully insured groups (including Level-Funded plans) with active prescription drug coverage in 2025 will be consistent with our approach for the reporting years of 2020, 2021, 2022, 2023 and 2024 submitted to CMS. For Fully Insured Groups, Horizon will:
Horizon has determined that there is sufficient internally captured data regarding the number of members in an insured plan, the life year’s calculation, premiums paid, rates, contributions, etc. to produce information for the D1 columns. How this applies to Self-Insured Group Plans Horizon’s approach to CAA RxDC for self-insured groups with active prescription drug coverage in 2025 will be consistent with our approach for the June 1, 2025 submission of 2024 data to CMS. Self-insured plans will have to continue to submit the:
Going forward, Horizon will review any additional clarification and guidance to ensure compliance with the RxDC requirements and will update their approach, if needed for future submissions. |
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| Humana | Pending Carrier Response | |||
| Independence Blue Cross (IBC) |
For the June 1, 2026 Section 204 RxDC submission to the Centers for Medicare & Medicaid Services (CMS), Independence Blue Cross (IBX) will report the actual premium amounts paid by the employer versus the actual premium amounts paid by members in 2025. Please note, both insured and self-funded customers must submit their data through our online form by May 1, 2026. The data must include:
IBX will produce and submit files P2, D1, and D2 for both insured and self-funded customers based on the data they currently have within our systems for the timeframes required for the reports. If a self-funded customer has OptumRx as their PBM, OptumRx will provide files D3 through D8 to IBX. IBX will submit all files on behalf of insured customers. IBX will submit the files to CMS in one reporting package. For self‑funded customers who carve out prescription drug benefits, data for files D3 through D8 will not be included in our submission. In addition, we will be sending this information to customers via email. We are sharing this with you for awareness only. Please note that, if a customer does not provide us with the requested data by May 1, IBX will submit the report to CMS without the customer’s data. Failure to respond with complete and correct information will impact IBX’s ability to report accurately on the customer’s behalf. IBX will not be responsible for any liability associated with an inaccurate report. It may be necessary for the customer to submit this information to CMS directly after May 1. |
For the June 1, 2026 Section 204 RxDC submission to the Centers for Medicare & Medicaid Services (CMS), Independence Blue Cross (IBX) will report the actual premium amounts paid by the employer versus the actual premium amounts paid by members in 2025. Please note, both insured and self-funded customers must submit their data through our online form by May 1, 2026. The data must include:
IBX will produce and submit files P2, D1, and D2 for both insured and self-funded customers based on the data they currently have within our systems for the timeframes required for the reports. If a self-funded customer has OptumRx as their PBM, OptumRx will provide files D3 through D8 to IBX. IBX will submit all files on behalf of insured customers. IBX will submit the files to CMS in one reporting package. For self‑funded customers who carve out prescription drug benefits, data for files D3 through D8 will not be included in our submission. In addition, we will be sending this information to customers via email. We are sharing this with you for awareness only. Please note that, if a customer does not provide us with the requested data by May 1, IBX will submit the report to CMS without the customer’s data. Failure to respond with complete and correct information will impact IBX’s ability to report accurately on the customer’s behalf. IBX will not be responsible for any liability associated with an inaccurate report. It may be necessary for the customer to submit this information to CMS directly after May 1. |
Please note, both insured and self-funded customers must submit their data through our online form by May 1, 2026. | |
| Independence Administrators (IA) | Pending Carrier Response | |||
| Oscar | Pending Carrier Response | |||
| UnitedHealthcare /Oxford | UHC/Oxford: CAA’s RxDC RFI Required by 3/31/26
UnitedHealthcare/Oxford requests your support in completing a few necessary questions in the Prescription Drug Data Collection (RxDC) RFI now available on the employer/broker portals until March 31, 2026. What’s Required:
Note: UMR customers received a customer-specific link to an RFI in an email from their UMR Strategic Account Executive (SAE). UMR customers must also complete the RFI by the March 31 deadline. To facilitate this process for UHC customers, we recommend using the RxDC RFI worksheet to gather the required data in advance. |
UHC/Oxford: CAA’s RxDC RFI Required by 3/31/26 UnitedHealthcare/Oxford requests your support in completing a few necessary questions in the Prescription Drug Data Collection (RxDC) RFI now available on the employer/broker portals until March 31, 2026. What’s Required:
Note: UMR customers received a customer-specific link to an RFI in an email from their UMR Strategic Account Executive (SAE). UMR customers must also complete the RFI by the March 31 deadline. To facilitate this process for UHC customers, we recommend using the RxDC RFI worksheet to gather the required data in advance. |
To facilitate this process for UHC customers, we recommend using the RxDC RFI worksheet to gather the required data in advance. | To facilitate this process please refer to the following helpful resources: RxDC Brainshark Information video, RxDC Guide, and external RxDC FAQs about the CMS RxDC requirements and the process for you to submit data to UHC. You can watch the video at your convenience, review any information you need, and easily print out any resources for future reference. |