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Legal Alert: RxDC Reporting Due June 1st
Compliance News
Thursday, March 05 2026
With the 2025 reference year Prescription Drug Data Collection (RxDC) reporting deadline approaching in June, plan sponsors should re-familiarize themselves with the reporting requirements. As of the date of this alert, the reference year 2025 RxDC Reporting Instructions have not been released; however, plan sponsors can use the 2024 reference year instructions (which were for reporting in 2025) as guidance until the new instructions are released.
As a reminder, the Consolidated Appropriations Act, 2021 includes a provision that requires group health plans and health insurance issuers (collectively “plans and issuers”) to report certain specified data related to prescription drug and other healthcare spending. The deadline to submit reporting for calendar year 2025 is June 1, 2026 (and continues each June 1st thereafter).
Next Steps for Employers
In anticipation of the June 1, 2026 deadline, plan sponsors may already be receiving communications from their carriers, TPAs, PBMs and other vendors regarding their expectations for completing the reporting. In our experience, carriers, TPAs, PBMs, and other vendors have varying requirements and expectations of what they need from plan sponsors to successfully complete the reporting, and some may delegate some of the reporting responsibility to the plan sponsor. For example, if your insurance company, TPA, or PBM sent you a survey or questionnaire to collect information about plan numbers, premium, or funding types, it is likely that they are reporting the P2 and D1 files on your behalf. Therefore, we recommend the following:
Respond to any requests for information you may receive and coordinate with your vendors to understand their expectations to ensure all reporting is completed in full on behalf of the plan. Note: Some carriers require responses by early March.
If your vendor sent you an email or letter asking you to create a HIOS account or stating that they will not submit P2 and D1 on your behalf, that means you must submit P2 and D1 directly to CMS (or engage a third-party to submit them for you). Thus, you and/or a third party submitting P2 or D1 on your behalf will need to follow the RxDC Reporting Instructions and timely complete the submission.
To Read Full Alert Click Here
As a reminder, the Consolidated Appropriations Act, 2021 includes a provision that requires group health plans and health insurance issuers (collectively “plans and issuers”) to report certain specified data related to prescription drug and other healthcare spending. The deadline to submit reporting for calendar year 2025 is June 1, 2026 (and continues each June 1st thereafter).
Next Steps for Employers
In anticipation of the June 1, 2026 deadline, plan sponsors may already be receiving communications from their carriers, TPAs, PBMs and other vendors regarding their expectations for completing the reporting. In our experience, carriers, TPAs, PBMs, and other vendors have varying requirements and expectations of what they need from plan sponsors to successfully complete the reporting, and some may delegate some of the reporting responsibility to the plan sponsor. For example, if your insurance company, TPA, or PBM sent you a survey or questionnaire to collect information about plan numbers, premium, or funding types, it is likely that they are reporting the P2 and D1 files on your behalf. Therefore, we recommend the following:
Respond to any requests for information you may receive and coordinate with your vendors to understand their expectations to ensure all reporting is completed in full on behalf of the plan. Note: Some carriers require responses by early March.
If your vendor sent you an email or letter asking you to create a HIOS account or stating that they will not submit P2 and D1 on your behalf, that means you must submit P2 and D1 directly to CMS (or engage a third-party to submit them for you). Thus, you and/or a third party submitting P2 or D1 on your behalf will need to follow the RxDC Reporting Instructions and timely complete the submission.
To Read Full Alert Click Here