Reminder for 2025 RxDC Data Requests

Each year, the Centers for Medicare and Medicaid Services (CMS) require certain group health plans to report prescription drug and healthcare spending data through a process called Prescription Drug Data Collection (RxDC). Insurance carriers, TPAs, and PBMs usually handle the actual filing to CMS, but they still need information from employers, specifically how much of last year’s medical and prescription drug costs were paid by employees versus the employer.

Who This Applies To

• Employers of any size that sponsor major medical group health plans with prescription drug coverage
• Does not apply to:
  • HRAs or ICHRAs
  • Retiree‑only plans
  • Excepted benefits such as standalone dental or vision
  • FSAs, HSAs, or EAPs

Important Reminders

• Each carrier or TPA sets its own deadline, so timely response is critical.
• Requests may come by email, portal notification, or newsletter—check spam folders if needed.
  • Carriers/TPAs with upcoming deadlines:
    • Auxiant 4/15
    • GHC 4/15
    • WPS 4/17
    • Prairie States 4/25
    • Quartz 4/30
  • Carriers/TPSs whose survey deadlines have closed:
    • Dean 3/10
    • Anthem 3/25
    • UHC 3/31
    • UMR 3/31

If an employer does not respond to the carrier/TPA by their deadline, the employer may be required to submit the missing contribution data directly to CMS by June 1, 2026. Click here for instructions. 

What Employers Need to Do

Most insurers and TPAs send employers a data request in early spring (often March) and set a firm deadline to respond.

Employers are typically asked to provide:

• Total employee contributions for the prior calendar year
• Total employer contributions for the prior calendar year

This includes contributions for COBRA participants. Even if your benefit plan does not run on a calendar year, the information must still be reported on a calendar‑year basis.

For self‑funded plans, the “premium equivalent” generally includes:

• Fixed plan costs
• Claims paid during the year (using either incurred or paid claims—consistently year to year)
• Less stop‑loss and pharmacy rebates retained by the plan

Changed Carriers in 2025?

If you changed insurers or TPAs during the 2025 calendar year, you may receive requests from both your current and former vendors. Employers must report to each for their portion of the year.

Bottom Line

RxDC reporting is required every year, and while vendors handle most of the work, employers must respond to contribution data requests. Keep an eye out for requests and follow up with your HG service team if you haven’t received one.