January 19, 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.
- Plan lists
| P1 |
Individual and student market plans |
| P2 |
Group health plan list |
| P3 |
FEHB (federal employee health benefit) plan list |
- 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 |
- 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.
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 insured, OptiFlex, and self-funded group business except as noted below.
Pharmacy carveout groups
Premera’s submission included the following reporting for groups that carveout pharmacy:
- P2-Group Health Plan List
- D1-Premium and Life Years
- D2-Spending by Category
- Narrative response
Clients with carveout 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.