RxDC Reporting Due June 1, 2026 

The Centers for Medicare and Medicaid Services (CMS) has updated the Prescription Drug Data Collection (RxDC) resources. The updates include changes to the RxDC Reporting Instructions and new RxDC templates and data dictionary. 

As a reminder, the RxDC reporting was established as part of the transparency rules under the Consolidated Appropriations Act 2021 (CAA). RxDC requires employer-sponsored health plans and insurance issuers to report specific health plan and prescription drug data to CMS annually by June 1st. The required information includes data on spending, premiums, cost-sharing, the most frequently prescribed drugs, and rebates received from manufacturers and covers data from the preceding calendar year. 

For many plan sponsors, the carriers, pharmacy benefit managers (PBMs) and/or third party administrators (TPAs) will collect and submit the RxDC reporting on the plan sponsor’s behalf. With that said, these entities may require information from the plan sponsor in order to complete the submission. Plan sponsors should monitor whether their carriers have reached out regarding additional data collection and a due date for opting in or out of the service as the due date for the data collection varies based on the carrier. 

In the event the carrier will not upload on the plan’s behalf and the plan sponsor needs to complete the RxDC reporting directly, an account must be created in CMS’s Health Insurance Oversight System (HIOS). The HIOS system may take up to two weeks to generate an account, so plan sponsors should create the account sooner rather than later to ensure they have enough time to collect the necessary information and complete submission. 

Innovative is working with our clients’ carriers, PBMs, TPAs to determine whether they will be submitting on employers’ behalf. For additional information please reach out to your Innovative Account Team.  

Questions or assistance with the upload can be directed to icomply@ibpllc.com.