The Consolidated Appropriations Act of 2021 requires employer health plans to submit annual prescription drug and health care spending data to CMS. Known as RxDC (Prescription Drug Data Collection), this reporting applies to both self-funded and fully-insured plans. The plan sponsor remains legally responsible for compliance even when the TPA or PBM submits on the plan's behalf.
Annual deadline
RxDC data for the prior plan year is due to CMS by June 1 each year. For calendar-year plans, the 2025 plan year data is due June 1, 2026. Submissions are made through the CMS Health Insurance Oversight System (HIOS).
What data must be submitted
RxDC requires eight data elements (D1–D8). Self-funded plans typically rely on their TPA for medical data and their PBM for pharmacy data.
D1
General plan information: Plan name, plan year, enrollment counts, premium equivalents, and total spending.
D2
Spending by category: Total spending broken down by hospital, primary care, specialty care, prescription drugs, and other.
D3
Top 50 drugs by spend: The 50 most costly drugs by total plan spending, including net spend after rebates.
D4
Top 50 drugs by utilization: The 50 most frequently dispensed drugs by prescription count.
D5
Top 50 drugs by spend increase: The 50 drugs with the largest year-over-year increase in total plan spending.
D6
Rebates and other remuneration: Total rebates, fees, and other remuneration received from drug manufacturers, broken out by therapeutic class.
D7
Average monthly premiums: Average monthly premium equivalents for single and family coverage.
D8
Life-years and spending: Total life-years covered and total spending for the plan year.
Who submits for self-funded plans
Plan sponsor: Legally responsible for submission. Can delegate to TPA or PBM but cannot transfer liability.
TPA: Typically submits D1, D2, D7, D8 (medical and enrollment data) on behalf of the plan.
PBM: Typically submits D3, D4, D5, D6 (drug utilization and rebate data) on behalf of the plan.
Issuer (fully-insured): The insurance carrier submits all data elements on behalf of fully-insured plans.
Common RxDC compliance mistakes
Assuming the TPA or PBM submitted without obtaining written confirmation
Missing the June 1 deadline because no one owns the submission process internally
Failing to confirm that rebate data (D6) was submitted — PBMs sometimes omit this
Not retaining submission confirmation records for audit purposes
Overlooking RxDC for newly self-funded plans in their first plan year
Confirm your RxDC submission status
Use our free compliance tools to verify your plan's CAA reporting obligations and identify any gaps.
