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 things to 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 break-downs:
- News announcement
- Warner Pacific webinar with expert and attorney Marilyn Monahan
- Marilyn Monahan Presentation: Quick Links
- Departments of Labor, Health and Human Services, and the Treasury
- Centers for Medicare & Medicaid Services
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 most current information.
CARRIER* | EMPLOYER SURVEY | WHO IS REPORTING Fully Insured | WHO IS REPORTING Self/Level Funded/ASO | RESOURCES |
Aetna | Aetna Prescription Drug Data Collection Reporting Submission The survey must be completed by the March 31, 2025, deadline. | Carrier will report | Carrier will report | RxDC 2025 |
| Allstate | Employers were emailed a Survey Link. Please note: If your customers had another program or carrier for a portion of the year, they should contact that carrier regarding submission of the required data for that time.
The survey must be completed by the April 30, 2025, deadline. | Carrier will report | Carrier will report | If you have questions, please contact the Allstate Benefits Group Health Account Management team at 888-659-1859 or email ABGHFullyInsured@allstate.com (fully insured plans) or ngbsselffunded@ngic.com (self-funded plans |
Anthem | 2025 Prescription Drug Data Collection (RxDC) Submission Forms should be completed and submitted no later than March 28, 2025. | 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 (Full Insured) based on all the information they received. If a broker did not respond to the survey, their specific info would not be included in the aggregate filing. | Employer must report. | Requests to collect 2024 CAA D1 prescription drug data |
Blue Shield of California | Complete the survey by logging in to Employer Connection or via the Prescription Drug & Healthcare Spending Survey using their group ID and following web key: #25yr24 The deadline to submit information is April 19, 2025. | 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. | Refer to submission grid | Group Broker Update |
Cigna | No survey announced for 2025 | Carrier will report | Carrier will report | |
Health Net | No survey announced for 2025 | Carrier will report | N/A | Health Net's 2024 RxDC Report Submission is Due June 1, 2025 |
Kaiser Permanente | Kaiser Permanente RxDC Data Collection Form The survey must be completed by the March 31, 2025, deadline. | Carrier will report | Carrier will report | Pharmacy Reporting (RxDC) Frequently Asked Questions (FAQs) (kp.org) |
Sharp Health Plan | No survey announced for 2025 | Carrier will report | N/A | |
Sutter Health Plan | No survey announced for 2025 | Carrier will report | N/A | |
UnitedHealthcare | To access the RFI tool, the employer must go to the CAA Prescription Drug Data Collection (RxDC) RFI Tool located on the employer/broker portal. The RFI must be completed by the March 31, 2025, deadline. | Carrier will report | Carrier will report | UHC Approach to CAA Pharmacy Benefits and Costs Reporting Guide |
Western Health Advantage | No survey announced for 2025 | Carrier will report | 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 both 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 1st.
Questions?
Call your Warner Pacific Sales Executive at (800) 801-2300.