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RxDC Guide: Pharmacy Data Collection Under The CAA
Carrier Updates
Tuesday, February 17 2026
The Consolidated Appropriations Act of 2021 (CAA) added pharmacy reporting requirements under the Internal Revenue Code, ERISA, and the PHSA. To help brokers and groups navigate these requirements, we've created a RxDC guide.
RxDC reporting deadlines are different for each carrier. Check out our RxDC Guide that organizes carrier deadlines, links to the employer survey, and additional information about this requirement from our carriers. These requirement deadlines are coming up, review the RxDC guide below.
Please note this is guide is for fully insured plans.
For more information about Pharmacy Data Collection Under the CAA read our Whitepaper here.
Learn more about this from the Centers for Medicare & Medicaid Services here
| Carrier | Who's Reporting | Employer Survey Link | Survey Due Date | Resources |
|---|---|---|---|---|
| Aetna | Carrier will report | View survey here | 3/31/26 | |
| Anthem | Carrier will report | Surveys were sent 2/16/26 View survey here |
3/25/26 | Anthem CAA Transparency Client FAQ |
| Blue Shield | Carrier will report | Survey is on Employer Connection Portal or View survey here | 4/10/26 | |
| California Choice | Please refer to enrolled carrier | Refer to specific carrier's guideline | N/A | |
| Covered California Small Business | Please refer to enrolled carrier | Refer to specific carrier's guideline | N/A | |
| Health Net | Carrier will report | No survey required | N/A | Health Net will meet all regulatory obligations for 2025 reporting due June 1, 2026. The Plan will not require any data from employer groups. |
| Humana | Carrier will report | Not released yet | ||
| Kaiser Permanente | Carrier will report | Survey is on KP employer portal | 3/31/26 | Kaiser RxDC FAQ |
| MediExcel | Carrier will report | MediExcel has reached out to groups | 5/5/26 | Employers and brokers can reach out to rxdc@mediexcel.com for more information. |
| Sharp Health Plan | Carrier will report | Email will be sent 3/17/26 | 4/17/26 | |
| United Healthcare | Carrier will report | UHC will send via online RFI tool. Customers will enter contribution data through the customer/broker portal. | 3/31/26 | United Heathcare RxDC FAQ |