The Consolidated Appropriations Act, 2021 created a data collection (RxDC) requirement for insurance companies, pharmacy benefit managers (PBMs), and employers sponsoring group health plans. These entities must submit detailed information about prescription drug and health care spending on an annual basis to the Department of Health and Human Services (HHS).

RxDC reports include a file of plan information (P2), details about the plan’s enrollment information and allocation of premium dollars (D1), plus seven additional data files (D2-D8) that reflect statistics about the plan’s prescription drug usage and medical claims data. The report for the 2023 reference year, which is due by June 1, 2024, contains information based on what happened in calendar year 2023.

Employers working with a health insurer, TPA, or PBM to submit D1 files on their behalf will likely encounter a tight deadline to give their vendor employer-specific information for these filings. For employers whose carrier/TPA/PBM is unwilling or unable to submit D1 on their behalf or for those who have missed their vendor’s deadline, CXC is available to prepare and submit D1 and P2 files for your organization.