Sarah Borders, CEBS May 31, 2023 5 min read

Prescription Drug Data Collection (RxDC) Reporting Requirement Due June 1

Act now for your CMS submission due June 1, 2023!

Under Section 204 of the Consolidated Appropriations Act, insurance companies and employer-based health plans must submit information about prescription drugs and health care spending to the Centers for Medicare & Medicaid Services (CMS) by June of each year for the prior year’s coverage (also known as the “Reference Year”). This is known as the Prescription Drug Data Collection (RxDC) Report.

Beginning with the June 1, 2023 submission, employers must report the average monthly premium they and their employees paid the prior year.

If you did not respond to your carrier’s requests for information in April/May, you will need to report this information directly to CMS by creating a Health Insurance Oversight System (HIOS) account. You must submit P2: Group Health Plan List (columns A – R) and D1: Premium and Life Years (columns A – F) on the portal by June 1, 2023.

We strongly recommend that you initiate this process now, to allow time for CMS account set up and time to address any questions that may arise for you during submission. PLEASE NOTE, you may be required to have more than one individual for your organization setup in HIOS. Please review the FAQs on page 33 to confirm if that is needed for your organization.


Create Your HIOS Account Here


Click to download the P2 and D1 templates. Refer to the RxDC Data Dictionary for an explanation of the P2 and D1 columns. For more information, including the RxDC Reporting Instructions, and HIOS Manuals, you may visit CMS’s website. Failure to report to CMS could result in the employer being subject to penalties.


If you have any questions, please call a member of your HG Account team.


Sarah Borders, CEBS

Principal, Benefits Compliance Solutions. Sarah has spent the last 15 years in the employee benefits industry, has numerous designations and serves on NAHU’s Employer Working Group Subcommittee and is an active board member of Austin AHU. She recently stepped down as Vice President of Benefits Compliance at one of the nation's largest brokerage firms to start her own compliance consulting practice. Her designations include an active license with the Texas Department of Insurance, CEBS (Certified Employee Benefits Specialist), Certified Health Care Reform Professional, HIPAA certification and Health Care Service Associate. She holds an MBA from Texas A&M Corpus Christi and a BA from University of Incarnate Word. Her consulting firm, Benefits Compliance Solutions, partners with employers to identify unknown risks and avoid hundreds of thousands of dollars in fines and lawsuits from failure to comply with their healthplan obligations.