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How 2025 RxDC Reporting Will Impact Employers and How to Prepare

May 22, 2025

Employer reviewing healthcare data for RxDC reporting

Employers offering group health plans must report detailed information on prescription drugs and healthcare spending annually to the Centers for Medicare & Medicaid Services (CMS). This process is called Prescription Drug Data Collection, or RxDC reporting.

The upcoming RxDC report, which must include data from the 2024 calendar year, is due by Sunday, June 1, 2025. Preparing early helps avoid errors and makes the process easier to manage. This blog explains the current rules, recent changes, and critical steps employers can take to prepare for the 2025 RxDC reporting deadline.

What Employers Must Include in the RxDC Submission

The RxDC report consists of several files, each containing specific data requirements. Some of these files focus on basic plan-level information, such as the start and end dates of the plan year, enrollment figures, and premium amounts. Other files request more detailed data regarding the structure of the medical and pharmacy benefits offered by the health plan, along with the associated spending. By gathering this information, the report provides CMS with a comprehensive overview of the healthcare and prescription drug expenses within employer-sponsored health plans.

Third-Party Involvement in RxDC Reporting

Many employers work with third-party vendors—such as insurance issuers, third-party administrators (TPAs), and pharmacy benefit managers (PBMs)—to submit their RxDC reports. Depending on the setup, different vendors may handle different parts of the report. For example, a self-insured employer may use both a TPA and a PBM for various sections. The RxDC report is considered complete once CMS receives all required files, no matter how many third parties are involved.

Preparing for 2025 RxDC Reporting: Key Considerations for Employers

  • Submission Requirements: Employers must annually submit the Prescription Drug Data Collection (RxDC) report to CMS. Many employers rely on third parties—such as issuers, TPAs, and PBMs—to handle the submission process.
  • Responsibility of Employers: Even if third parties handle the submission, the employer is still responsible for ensuring the report is completed correctly and submitted on time. Employers should ensure their contracts clearly define these responsibilities.
  • Vendor Coordination: Employers should contact their issuers, TPAs, or PBMs to confirm their commitment to submitting the required files. It’s essential to confirm that third-party agreements clearly outline RxDC reporting responsibilities.
  • Self-Insured Health Plans: Employers with self-insured health plans remain accountable for the RxDC reporting. They must monitor vendor compliance and promptly provide any requested data, such as enrollment and premium details.

What Happens If RxDC Reporting Is Not Submitted on Time?

Employers often rely on third parties to handle RxDC report submissions. However, employers must provide key data—such as enrollment numbers and premium amounts—to assist with the process. It’s important to watch for data requests or surveys from vendors and respond promptly. For self-funded plans, employers are ultimately responsible for ensuring the complete and accurate submission of the RxDC report.

Conclusion: Ensure Compliance with RxDC Reporting

Here’s How The CBC Health Insurance Marketplace for Costco Members Can Help

With the 2025 deadline approaching, taking proactive steps now will ensure your report is accurate, timely, and meets all necessary requirements. Proper preparation and understanding of the RxDC reporting process are crucial for employers to stay compliant and avoid potential penalties.

The CBC Health Insurance Marketplace for Costco Members offers the expertise and support you need to meet all RxDC reporting requirements. We help simplify the reporting process by assisting with data gathering, coordinating with third-party vendors, and ensuring compliance every step of the way. By partnering with us, you can avoid the stress of last-minute complications and rest easy knowing your report is in good hands. Contact us today to ensure a smooth, hassle-free submission.

FAQs

Q1. What Is the Purpose of RxDC Reporting?

A1. RxDC (Prescription Drug Data Collection) reporting provides the Centers for Medicare & Medicaid Services (CMS) with detailed information about prescription drug spending, healthcare benefits, and health plan structures. This data helps CMS monitor and understand how prescription drugs and healthcare expenses are distributed across employer-sponsored health plans, which informs policy decisions and regulatory compliance.

Q2. Who is Responsible for Ensuring the Accuracy of RxDC Reports?

A2. While many employers delegate the task of submitting RxDC reports to third parties like insurance issuers, TPAs, or PBMs, the ultimate responsibility for ensuring the accuracy and timeliness of the report lies with the employer. Employers must supervise the process, ensure their third-party vendors follow through, and confirm that all necessary data is accurately submitted to CMS.

Q3. What Happens If an Employer Misses the RxDC Reporting Deadline?

A3. If the RxDC report is not submitted on time or is incomplete, it can result in penalties and regulatory issues. For self-insured employers, failing to meet the deadline can lead to compliance violations, including fines or other legal consequences. Employers should communicate closely with their third-party vendors to avoid these issues.

Q4. How Can Employers Ensure Their Third-Party Vendors Are Compliant with RxDC Reporting?

A4. Employers should have clear agreements with third-party vendors outlining their responsibilities regarding RxDC reporting. Regular communication and follow-up are critical. Employers should confirm that their vendors have a process for collecting necessary data, submitting reports on time, and responding to additional data requests from CMS.

Q5. Can Employers Modify or Update Submitted RxDC Data?

A5. Once an RxDC report has been submitted, employers can request to correct or modify data if inaccuracies are identified. Employers should work closely with their vendors to address discrepancies promptly and ensure that CMS receives accurate, updated information to avoid potential issues with compliance or reporting.

 

 


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Attention: This website is operated by Custom Benefit Consultants, Inc. and is not the Health Insurance Marketplace website. In offering this website, Custom Benefit Consultants, Inc. is required to comply with all applicable federal law, including the standards established under 45 CFR 155.220(c) and (d) and standards established under 45 CFR 155.260 to protect the privacy and security of personally identifiable information. This website may not display all data on Qualified Health Plans (QHPs) being offered in your state through the Health Insurance Marketplace website. To see all available data on QHP options in your state, go to the Health Insurance Marketplace website at HealthCare.gov.

 

Costco Insurance Agency, Inc. is a licensed insurance agent. Insurance plans are offered by licensed insurance companies or health maintenance organizations. Health insurance plans on The CBC Health Insurance Marketplace for Costco Members are brokered and /or serviced by CBC Benefit & Insurance Services; CA License #: 0D75486 and Costco Wholesale Corp. License #: 0C28248. Costco Insurance Agency License #: 0D08407.

 

If you would like assistance in another language, please visit Healthcare.gov or contact us at (855) 332-3821 to access our language line.

 

All insurance products are issued by licensed insurance companies and made available to applicants through Costco Insurance Agency, Inc., which receives a commission from insurers to distribute these products. Your insurance policy, not the information on this site, determine the applicable terms and conditions of the insurance product. Neither Costco Insurance Agency, Inc. nor its affiliates guarantee the services of any insurance company.