Prescription Drug Data Collection (RxDC) Reporting Carrier Guidelines

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: 04.17.2025

What is Prescription Drug Data Collection (RxDC) Reporting?

Under Section 204 (of Title II, Division BB) of the Consolidated Appropriations Act, 2021 (CAA), insurance companies and employer-based health plans must submit information about prescription drugs and health care spending. This data submission is called the Prescription Drug Data Collection Reporting, also referred to as RxDC Reporting.

In addition to collecting information about prescription drugs, it also reports on information about health care services spending and premium paid by employers and members.

CAA Prescription Drug Reporting is required to be submitted annually no later than June 1^st to the Centers for Medicare and Medicaid Services (CMS).

Who is responsible for Prescription Drug Data Collection (RxDC) Reporting?

Fully-Insured Groups

For fully-insured groups, carriers are largely taking on the responsibility of reporting, but employers must still ensure that the carrier is filing on their behalf. It is important for plan sponsors to keep any written communication from the carrier that states how they are complying with the reporting requirement on behalf of fully-insured plans.

Self-Insured Groups / Level-Funded Plans

Self-insured groups, including level-funded plans, have more responsibility in ensuring the reporting is completed. We recommend that self-insured (and level-funded) plan sponsors contact their carrier, TPA and/or PBMs to ensure how these vendors can assist with the reporting requirement.

Self-insured plans may enter into a written agreement with their vendors to fulfill the reporting function on behalf of the plan; however, the plan sponsor remains liable for any failures.

Prescription Drug Data Collection Reporting (RxDC) Requirements by Carrier

Reference Year 2024 Reporting is Due June 1, 2025

Each carrier may have different guidelines and details for how they are handling RxDC reporting. For your reference, we have prepared the carrier RxDC reporting chart below which outlines carrier-specific guidelines and resources.

If a carrier survey remains open after the deadline, there is no guarantee that the information will be received by the carrier.

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: Total premium paid by members for the reference year Total premium paid by employer for the reference year Funding arrangement Issuer Name/Legal Entity	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: Total premium paid by members for the reference year Total premium paid by employer for the reference year Funding arrangement Issuer Name/Legal Entity If a self-insured plan sponsor requests to be excluded from Aetna’s D1 file, employers do not need to complete this data collection process. Instead, plan sponsors should contact their account representative to request an exception.	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	EmblemHealth will email clients details and a survey link to fully insured and self-funded groups in mid-April 2025 to collect required data. The survey must be completed by May 9, 2025.	EmblemHealth will email clients details and a survey link to fully insured and self-funded groups in mid-April 2025 to collect required data. The survey must be completed by May 9, 2025.	The survey in the email must be completed by May 9, 2025.	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.	UHC RxDC RFI Worksheet UHC RxDC Information

For further details, visit the CMS CAA Prescription Drug Reporting (RxDC) resources below.

If you have any questions, our Employer Services and Compliance Team is here to help. Contact us today.