Employer group health plans must make an annual disclosure of the plan's prescription drug and healthcare spending to the Centers for Medicare & Medicaid Services (CMS). The disclosure, called the Prescription Drug Data Collection (RxDC) report, is due no later than June 1, 2024.
The RxDC report is a series of data files containing plan information, employer information, financial information (such as premiums, fees, drug costs, cost-sharing, and rebates), and aggregated claim information (such as number of claims, number of unique members, and dosage units). Plans are required to submit the RxDC report through CMS's Health Insurance Oversight System (HIOS). CMS created an online resource page with instructions for submitting the RxDC report here.
An employer group health plan may contract with a third party to submit the RxDC report on the plan's behalf. In our experience, virtually all insurance companies submit the report on behalf of their fully-insured plans. Employers with self-funded plans typically have an agreement with their third-party administrator, broker, or benefit consultant, who will file on the plans' behalf.
Employers who have engaged a third party should ask whether any additional information is needed to complete and file the RxDC report. Employers who intend to file the RxDC report themselves should register with HIOS, review the reporting instructions, gather the required data, and otherwise prepare to submit the required information in the required format by June 1.
CMS uses the information from the disclosures to:
- Identify major drivers of increases in prescription drug and healthcare spending
- Understand how prescription drug rebates impact premiums and out-of-pocket costs and
- Promote transparency in prescription drug pricing
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If you have questions or concerns regarding this client alert, please contact the authors, any member of Venable's Employee Benefits and Executive Compensation Group, or your regular Venable lawyer.