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: 03.31.2025
CARRIER | REPORTING FULLY-INSURED |
REPORTING SELF/LEVEL-FUNDED |
EMPLOYER SURVEYS | RESOURCES |
---|---|---|---|---|
Aetna | Starting Friday, January 31, Aetna will begin emailing plan sponsors to collect information for this years report. In 2025, Aetna will require the following data from all plan sponsors included in Aetna’s D1 file:
|
Starting Friday, January 31, Aetna will begin emailing plan sponsors to collect information for this years report. In 2025, Aetna will require the following data from all plan sponsors included in Aetna’s D1 file:
|
Required survey due March 31: Aetna RxDC Data Collection Form If any plan sponsor does not provide the requested data by March 31, Aetna will submit the report without the required plan sponsor data. Failure to respond with complete and correct information will impact Aetna's ability to accurately report on the plan sponsor’s behalf, and Aetna will not be responsible for any liability associated with the inaccurate report. It may be necessary for the employer to submit this information to CMS directly. |
|
AmeriHealth NJ | Customers must submit their data through via online form by May 1, 2025. NOTE: Survey should be submitted by midnight 4/30/2025 to be received by the carrier on 5/1/2025. |
Customers must submit their data through via online form by May 1, 2025. NOTE: Survey should be submitted by midnight 4/30/2025 to be received by the carrier on 5/1/2025. |
RxDC Survey form | 2025 Prescription Drug Data Collection (RxDC) Information |
Anthem NY | The week of February 17 – Fully Insured clients Anthem will email Fully Insured National Account, Large Group, and Small Group commercial clients, as well as clients with Minimum Premium, MEWA, and Anthem Balanced Funding plans. The email will include a link to an online form for these clients to provide the information Anthem needs to complete the filings on their behalf. |
The week of February 17 – ASO client D1 opt-in Anthem will email ASO Large Group and National Account clients and provide a link for them to request that Anthem file their 2024 D1 Premium and Life Years report. For those who opt-in, Anthem will submit the aggregated data by market segment on their behalf for the benefits they administer and maintain. |
Fully-Insured Groups Survey Survey due March 19, 2025. |
|
Anthem CT | The week of February 17 – Fully Insured clients Anthem will email Fully Insured National Account, Large Group, and Small Group commercial clients, as well as clients with Minimum Premium, MEWA, and Anthem Balanced Funding plans. The email will include a link to an online form for these clients to provide the information Anthem needs to complete the filings on their behalf. |
The week of February 17 – ASO client D1 opt-in Anthem will email ASO Large Group and National Account clients and provide a link for them to request that Anthem file their 2024 D1 Premium and Life Years report. For those who opt-in, Anthem will submit the aggregated data by market segment on their behalf for the benefits they administer and maintain. |
Will be in email from carrier. | |
BCBS of North Carolina (Blue Cross NC) |
Pending carrier response. | Pending carrier response. | Pending carrier response. | |
CareFirst BCBS | CareFirst will annually submit all RxDC files* on behalf of our fully insured clients and our self-insured clients that are not contracted under a Shared Processing Services Agreement or Network Lease Agreement. CareFirst will submit data for all applicable clients that contracted with us for any portion of the reference year. *Certain client data will only be included on the D1 Premium and Life-Years file submission if any request for that data is provided by the deadline provided at the time of the request. In lieu of providing the data, clients will have an option to opt out of having CareFirst submit their D1 data. |
CareFirst will annually submit all RxDC files* on behalf of our fully insured clients and our self-insured clients that are not contracted under a Shared Processing Services Agreement or Network Lease Agreement. CareFirst will submit data for all applicable clients that contracted with us for any portion of the reference year. *Certain client data will only be included on the D1 Premium and Life-Years file submission if any request for that data is provided by the deadline provided at the time of the request. In lieu of providing the data, clients will have an option to opt out of having CareFirst submit their D1 data. |
No survey is required. | CareFirst RxDC Reference Page |
Cigna | Carrier will report. | Carrier will report. | No survey is required. | |
Cigna + Oscar | Carrier will report. | N/A | No survey has been announced. | |
Cigna Administered by Oscar | Carrier will report. | N/A | No survey has been announced. | |
ConnectiCare | Carrier will report. | N/A | Details pending for 2025. | |
EmblemHealth | Carrier will report. Will require additional information from clients via survey. |
Carrier will report. Will require additional information from clients via survey. |
EmblemHealth will send a survey to all group clients in April 2025 to collect this required data. | EmblemHealth CAA page |
Florida Blue | Carrier will report. Will require additional information from clients via survey. |
Carrier will report. Will require additional information from clients via survey. |
To facilitate this process, there are three distinct surveys tailored to your specific group type: Fully Insured, MPP, and ASO/Self-Insured groups. You will receive an email with a unique link to access your designated survey. The survey will contain pre-populated information that we ask you to review and confirm. If any information is incorrect, you will have the opportunity to update it with the correct details. |
Instruction to Complete the Consolidated Appropriations Act (CAA) Section 204 Pharmacy Reporting |
Highmark | Carrier will report. Will require additional information from clients via survey. The deadline to submit the required information is April 14, 2025, at 11:59 PM EST. Late submissions will not be accepted. Data Required: Fully Insured Clients: Requires average monthly premiums paid by the employer and by members for calendar year 2024. |
Carrier will report. Will require additional information from clients via survey. The deadline to submit the required information is April 14, 2025, at 11:59 PM EST. Late submissions will not be accepted. Self-Insured (ASO) Clients: Requires more comprehensive data including total premium equivalents, ASO and TPA fees, stop-loss premiums, and average monthly premiums paid by the employer and members for calendar year 2024. ASO clients with carved-out pharmacy benefits must work with their Pharmacy Benefit Managers (PBMs) to submit the necessary pharmacy benefit data files directly to CMS. Highmark will not submit this data on their behalf. |
Highmark RxDC Survey |
Highmark Producer Blast - RxDC |
Horizon BCBSNJ | Carrier will report. | Carrier will report. Will not collect external carrier files to aggregate data. Will not submit D3-D8 Pharmacy data files if Prime Therapeutics is not the designated PBM. |
No survey is required. | Horizon BCBSNJ CAA RxDC |
Humana | Carrier will report. | Carrier will report. | Pending survey release. | |
Independence Blue Cross (IBC) | Customers must submit their data through via online form by May 1, 2025. NOTE: Survey should be submitted by midnight 4/30/2025 to be received by the carrier on 5/1/2025. |
Customers must submit their data through via online form by May 1, 2025. NOTE: Survey should be submitted by midnight 4/30/2025 to be received by the carrier on 5/1/2025. |
RxDC Survey form | 2025 Prescription Drug Data Collection (RxDC) Information |
Independence Administrators (IA) | Pending carrier response. | Pending carrier response. | Pending carrier response. | Pending carrier response. |
Oscar | Pending carrier response. | Pending carrier response. | Pending carrier response. | |
UnitedHealthcare Oxford | Groups should use the RFI tool found on uhceservices.com to submit their information to us by the 3/31/25 deadline. If the deadline is missed, UHC will submit the data available that we have, but it will still be considered incomplete and the group will need to submit directly in to CMS themselves. |
Groups should use the RFI tool found on uhceservices.com to submit their information to us by the 3/31/25 deadline. If the deadline is missed, UHC will submit the data available that we have, but it will still be considered incomplete and the group will need to submit directly in to CMS themselves. |
No survey is needed. |