CAA Prescription Drug Reporting: What You Need to Know

What is prescription-drug reporting, and how does it affect you and your groups? Get the answers to these questions and more in this resource page.

What is Rx reporting?

Prescription-drug reporting is a federal mandate created by the Consolidated Appropriations Act of 2021, which was signed into law in December 2020. It requires insurance companies and group health plans to report prescription drug data to the government.

Why is the government doing this?

For years, prescription costs for drugs has been a hot topic. The federal government wants to use the data that will be reported to study the prescription drug industry; consider legislative or regulatory changes; and look at market concentration (i.e., essentially antitrust issues).

How does this affect agents and groups?

Insurance companies have sent a lot of questions and communications to groups about drug reporting. Some groups may not understand why this is happening. That’s where you come in: You can help guide your groups and facilitate the reporting process so they can meet their deadline.

Important note

Whether your group is fully insured or self-funded, they have to comply with this mandate.

Resources

Here are some important resources you can reference, including links to detailed breakdowns:

How Carriers Are Addressing the CAA Prescription Drug Reporting Requirement

Information about how carriers are addressing the CAA Prescription Drug Reporting requirement, as well as the employer obligations required for each carrier, are listed below. We are making updates to this list. Please check back frequently for the most current information.

Employer Survey

Who is reporting (Fully Insured)?

  • Carrier will report

Who is reporting (Self/Level Funded/ASO)?

  • Carrier will report

Resources

Employer Survey

Who is reporting (Fully Insured)?

  • Carrier will email Fully Insured National Account, Large Group, and Small Group commercial clients, as well as clients with Minimum Premium, MEWA, and Anthem Balanced Funding plans. The email will include a link to an online form for these clients to provide the information we need to complete the filings on their behalf.

  • Anthem is filing an aggregated response for all California Small Group (Fully Insured) based on all the information they received. If a broker did not respond to the survey, their specific information would not be included in the aggregate filing.

Who is reporting (Self/Level Funded/ASO)?

  • Employer must report

Resources

Employer Survey

  • Complete the survey by logging into Employer Connection or via the Prescription Drug & Healthcare Spending Survey using their group ID and following web key: #26yr25
    • The deadline to submit information is April 10, 2026. However, any updates to submissions can be made until April 19, 2026. The period between April 10, 2026, and April 19, 2026, is only for making updates to existing submissions made by the deadline.

Who is reporting (Fully Insured)?

  • Blue Shield of California is collecting D1 Premium Contribution data as part of the Consolidated Appropriations Act, Section 204 (2021) – Prescription Drug Cost Reporting regulation, on behalf of our employer groups.

Who is reporting (Self/Level Funded/ASO)?

  • N/A

Resources

Employer Survey

  • No survey announced for 2026

Who is reporting (Fully Insured)?

  • Carrier will report

Who is reporting (Self/Level Funded/ASO)?

  • Carrier will report

Resources

Employer Survey

2025 Submission Due June 1, 2026

  • The plan will not require any data from employer groups to complete Plan List (P2) and Data File (D1) submissions on behalf of clients.
  • The plan will not require any data from employer groups to complete Plan List (P2) and Data File (D1) submissions on behalf of clients.
  • The plan will not issue communications to members, groups regarding the RxDC filing (confirmation of filing completion, compliance, etc.), as this is not a regulatory requirement.
  • The plan will not establish contracts with groups regarding RxDC reporting, as this is not required by regulations.
  • Employer groups do not need to take any action or pay any fees to Health Net for this reporting.

Who is reporting (Fully Insured)?

  • Carrier will report

Who is reporting (Self/Level Funded/ASO)?

  • N/A

Resources

Employer Survey

Who is reporting (Fully Insured)?

  • Carrier will report

Who is reporting (Self/Level Funded/ASO)?

  • Carrier will report

Resources

Employer Survey

  • Employers will receive a Survey Link in April to confirm their business information.
  • Please note: Once the survey is completed, reporting will be submitted automatically on their behalf. The only action required from the group is to complete the survey and verify the group-level information to ensure compliance.
  • The survey must be completed by the April 30, 2026, deadline.

Who is reporting (Fully Insured)?

  • Carrier will report

Who is reporting (Self/Level Funded/ASO)?

  • Carrier will report

Employer Survey

  • We are doing things slightly differently this time around. We will be sending unique links to Employers, so it will be important that they not forward their links because their link will automatically populate with their group number and group name. The rest of the form will be fillable.

    The brokers will get a similar link like last year (but it will be new one), the form will not be prefilled so if any brokers want to fill out the form for their groups, they can complete and submit.

    In addition, when the form is submitted, they will get an automatic email confirming submission. If they need to make any updates to the information submitted, the employer can just open their link and resubmit the form again. We will use the last submitted link for reporting.

    Here is the timeline:

    3/17 broker alert 8am, Employer Alert 1pm.

    4/2 Follow up Alert

    4/14 Last call Alert

    4/17 Deadline to submit

    Please make sure brokers and employers are waiting to receive the email before they submit. In the past, we have seen people submit (using old links) prior to when we open the link and somehow their submission gets lost.

Who is reporting (Fully Insured)?

  • Carrier will report

Who is reporting (Self/Level Funded/ASO)?

  • N/A

Employer Survey

  • The Consolidated Appropriations Act of 2021 (Section 204) requires insurance companies and employer-based health plans to submit information to the federal government about premiums and cost-sharing.

    To meet this requirement, employer groups must submit information to Sutter Health Plan regarding the average monthly premiums paid on behalf of enrollees and the amount paid by enrollees each year.

    For calendar year 2025 reporting, please use the online Premium Reporting Form for employers, or their brokers, to conveniently submit the required information. We appreciate early reporting, if possible, with submissions due no later than March 1, 2026.

    If you have already submitted your clients’ premium reporting information, thank you for your response. 

Who is reporting (Fully Insured)?

  • Carrier will report

Who is reporting (Self/Level Funded/ASO)?

  • N/A

Employer Survey

  • To access the RFI tool, the employer must go to the CAA Prescription Drug Data Collection (RxDC) RFI Tool on the employer/broker portal.
    • The RFI must be completed by the March 31, 2026, deadline.

Who is reporting (Fully Insured)?

  • Carrier will report

Who is reporting (Self/Level Funded/ASO)?

  • Carrier will report

Resources

Employer Survey

  • WHA has updated the link for employers / brokers to update CAA RxDC Reporting for plan year 2025. In compliance with Section 204 of the Federal Consolidated Appropriations Act of 2021, health plans are required to submit information to the federal government regarding the average monthly premiums paid by employers on behalf of enrollees as well as average contributions paid by the enrollees each year. We are requesting to have this completed by April 15, 2026.

    2025 CAA Health Care Spending Data Collection for Reporting

Who is reporting (Fully Insured)?

  • WHA will be filing the report by June 2026 on behalf of our clients.

Who is reporting (Self/Level Funded/ASO)?

  • N/A

*Disclaimer: Please refer to carrier-specific guidelines for complete details and additional information.

Employer Group Responsibilities For Late Carrier Submissions

If the carrier submission deadline has passed and the required information has not been submitted, employer groups may be responsible for providing the survey data directly to CMS. In most cases, this will involve submitting the P2 and D1 files to CMS by June 1.

To determine the average premium paid by the employee and employer, refer to the CMS Instruction Guide (pages 21-22), which outlines the calculation process. The average premium amount paid by a member includes the employee and their dependents.

Important Notice: To ensure a smooth filing process, it is highly recommended that employers register on the website well in advance of the submission deadline. Keep in mind that registration verification may take several weeks. Disregarding the survey from the insurance carrier could result in the employer being held accountable for any delays or incomplete submissions.

For assistance with the submission process, visit the CMS Survey page. Additional information about RxDC reporting can be found on the CMS website.

To stay updated on announcements and register for training webinars, visit the Registration for Technical Assistance Portal (REGTAP). If you can't find the answer to your question in REGTAP, contact the help desk at 1-855-267-1515 or email them. Include "RxDC" in the body of the email for faster service. Responses are typically provided within the same day, with a full resolution expected within 1-2 weeks.

Annual reporting schedule

Reports are due annually on June 1.

Questions?

Call your Warner Pacific Sales Executive at (800) 801-2300.