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Article last updated: March 4, 2025.
Most of your clients have upcoming deadlines under the federal prescription drug benefits reporting (RxDC) requirements. Here’s a summary of the requirements, carrier support initiatives, and critical submission deadlines to ensure timely compliance.
Under Section 204 of the 2021 Consolidated Appropriations Act (CAA), insurance companies and employer-based health plans must submit information regarding prescription drug benefits and health care spending. The information must be submitted to the Centers for Medicare and Medicaid Services (CMS) by June 1st of each year for the prior year’s coverage.
The CMS requires the following information be submitted by insurance companies and employers:
Anthem will follow the same process as in prior years and will file on behalf of their fully insured and ASO clients for the benefits they administer and maintain. This includes ASO groups who opt-in to the D1 reporting. To submit all required information and ensure reporting accuracy, they will request some information from their clients.
Week of February 17th – Large Group, Small Group, and National Account clients were notified about required RxDC filings and necessary actions.
Early June 2025 – RxDC Filing Confirmation
For more information, please visit Anthem’s CAA/Transparency Resource Center.
Blue Shield will collect D1 Premium Contribution data from groups between February 19, 2025 and April 19, 2025. Blue Shield will also submit D2 for all groups and D3-D8 for groups with prescription drug benefits under a Blue Shield health benefit plan. If a group does not have prescription drug benefits with Blue Shield, they should coordinate submission of D3-D8 with their pharmacy/prescription drug benefits carrier.
Key Details
Who Needs to Submit The Survey?
Any group (or broker/delegate on behalf of the group) who would like Blue Shield to submit D1 Premium data on their behalf to the CMS. This includes:
Third-Party Administrators (TPAs) and Pharmacy Benefit Managers (PBMs) may assist in reporting. Groups that miss the deadline will not be included in Blue Shield’s filing and may be subject to non-compliance if they do not report the required data directly to the CMS by the June 1, 2025 deadline.
Other Details
Information Requested
Health Net will not require any data from employer groups to complete Plan List (P2) and Data File (DI) submissions with the CMS on behalf of their clients. No action or any fees are required by employer groups or brokers. This includes groups with members enrolled in Health Net through CaliforniaChoice.
Fully insured employer groups will need to complete the Kaiser Permanente RxDC data collection form by March 31, 2025.
Information Requested
Self-funded groups: Kaiser Permanente representatives will reach out to each self-funded group, via email, with instructions and offline forms that will be prepopulated with the group’s information along with blank fields for the group to complete and return to Kaiser Permanente.
Specific CA Small Groups: Covered California for Small Business (CCSB) and CaliforniaChoice groups do not need to complete the form as these exchanges will be providing the needed data for all the employers they serve, aggregated at the exchange level, to Kaiser Permanente.
Kaiser Permanente plans to submit all applicable reports and required responses for all employer groups to CMS by the June 1, 2025 deadline. To learn more, view the Kaiser Permanente RxDC FAQs.
Sharp Health Plan will request employer contribution data via a Request for Information (RFI) survey and will file on behalf of the group. Deadline: April 18, 2025.
UnitedHealthcare will complete the CAA Prescription Drug (RxDC) reporting for its fully insured and self-funded/level funded groups, including those with OptumRx as the integrated PBM. However, groups with these will need to complete the Request for Information (RFI) tool for RxDC reporting between February 1, 2025, and March 31, 2025.
To support its customers with this important filing, UnitedHealthcare will be submitting the P2 (Group Health Plan), D1 (Premium and Life Years) and D2 (Spending by Category) files for all employers who had active coverage during the reference year (2024). However, completion of the submission requires gathering some information not currently maintained in their system.
UnitedHealthcare will also submit the D3-D8 data files for customers with OptumRx as an integrated PBM. UnitedHealthcare has access to all data required to complete the submission of the D3-D8 data files. Customers who use any other PBM, including OptumRx Direct, must work with that PBM to submit the D3-D8 files.
Resources
Western Health Advantage will request employer contribution data via a Request for Information (RFI) survey and will file on behalf of the group. Deadline: April 15, 2025.
Covered California for Small Business (CCSB) serves as an administrator of their participating Health Plan Issuers and is not an insurance company nor an employer-based health plan. Therefore, CCSB is not subject to RxDC data collection requirements on behalf of their employer groups. Claremont recommends that the employer follow the reporting guidelines for the enrolled carrier(s).
CCSB’s Small Business Service Center is available to help with questions at 855.777.6782.
CaliforniaChoice serves as an administrator of their participating Health Plan Issuers and is not an insurance company nor an employer-based health plan. Therefore, CaliforniaChoice is not subject to RxDC data collection requirements on behalf of their employer groups.
Like last year, CaliforniaChoice is facilitating the RxDC for its employers and their plans for the 2024 reference year (reporting due June 1, 2025). CaliforniaChoice will coordinate directly with their carriers to facilitate all reporting obligations. There is no action required from the employer.
The carriers are actively assisting your clients with federal reporting compliance and will require specific information from each employer group. Watch for direct communication from the carriers and follow their instructions. If you or your clients need assistance we can connect you with appropriate carrier representatives.
Questions?
Contact The Answer Team at 800.696.4543 or info@claremontcompanies.com.
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