Prescription Drug Data Collection (RxDC) Reporting

  • January 12, 2023

    Under the Consolidated Appropriations Act, 2021 (CAA), health issuers offering group or individual health coverage and self-funded group health plans must submit detailed data on prescription drug pricing and healthcare spending. This data submission is called the Prescription Drug Data Collection (RxDC) Report.

    The RxDC report is due annually, beginning December 27, 2022 (for reference years 2020 and 2021), and then by June 1 of each subsequent year. Required entities must submit the report through a web portal managed by the Centers for Medicare & Medicaid Services (CMS), which will collect the data on behalf of the Departments of Health and Human Services, the Department of Labor, and the Department of the Treasury (the Departments).

    The reporting requirements include information intended to identify the significant drivers of increases in prescription drug and healthcare costs, increase understanding of how prescription drug rebates impact premiums and out-of-pocket costs, and improve prescription drug pricing transparency.

    What data is required?

    Plans, issuers, and carriers must submit one or more plan lists, eight data files, and a narrative response.

    1. Plan Lists
    P1 Individual and Student Market Plans
    P2 Group Health Plan list
    P3 FEHB (federal employee health benefit) plan list
    1. Data Files
    D1 Premium and Life Years
    D2 Spending by Category
    D3 Top 50 Most Frequent Brand Drugs
    D4 Top 50 Most Costly Drugs
    D5 Top 50 Drugs by Spending Increase
    D6 Rx Totals
    D7 Rx Rebates by Therapeutic Class
    D8 Rx Rebates for the Top 25 Drugs
    1. Narrative Response

    How will this data be used?

    The Department of Health and Human Services (HHS) must post a report on prescription drug reimbursements for plans and coverage, prescription drug pricing trends, and the role of prescription drug costs in contributing to premium increases or decreases under these plans or coverage. However, HHS will aggregate the information so that no drug or plan-specific information is made public.

    What’s the Premera approach?

    Fully insured, OptiFlex, and Self-funded business

    On December 23, 2022, Premera submitted the required plan lists, data files, and narrative responses for reference years 2020 and 2021 ahead of the December 27 deadline. The reporting included P2, D1-D8, and required narrative response for fully insured, OptiFlex, and self-funded group business except as noted below.

    Pharmacy Carve-out Groups

    Premera included the following reporting for groups that carve-out pharmacy:

    • P2-Group Health Plan List
    • D1-Premium and Life Years
    • D2-Spending by Category
    • Narrative response

    Clients with carve-out arrangements should coordinate with other carriers to ensure they report all required information.

    Terminated Groups

    Premera included reporting for all groups active during 2020 and/or 2021. The reporting did not include data for any periods in which the group was not covered by Premera.

    Average Premium Data

    The Departments will not enforce the requirement to report the average monthly premium paid by employers versus members for the 2020 and 2021 reference years if those data elements are unavailable. As a result, Premera did not include that information for the 2020 and 2021 reporting due December 27, 2022.

    Please contact your Premera account representative if you or your clients have questions about this requirement.

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