Sarah Borders April 10, 2026 5 min read

RxDC Submission to HIOS

If an employer missed the RxDC survey response deadline for their carrier to submit reporting on the employer’s behalf, or if the employer is otherwise responsible for submitting information, the following steps outline how to submit portions of RxDC directly to CMS.

Step One: To submit to CMS, the employer must first establish access to the CMS’s Health Insurance Oversight System (HIOS). This process can take roughly two weeks and involves providing personal information like social security number and authorization for a soft credit check with Experian for identity verification. Here is the link to the CMS User Guide for detailed instructions on setting up access to HIOS: CMS User Guide for Setting up Access to HIOS

Step Two: While awaiting access to HIOS, the employer can work on populating the information missing from what their carrier/TPA submitted. Visit the RxDC CMS webpage to access the RxDC Reporting Instructions and download the applicable RxDC Reporting Templates. Download templates D1 and P2 (see image below):

Step Three: In the D1 template:

  • Populate columns A through F.
    • Columns A through D identify the employer and plan. The instructions for these columns are straightforward.
    • Columns E and F are premium payments for the previous calendar year medical/Rx coverage divided by 12 (as paid by members in column E and as paid by the employer in column F). See image below.
  • The remaining D1 columns, G through K, should have been submitted for the employer by the carrier.

Step Four: Any files submitted to HIOS must be submitted with a P2, which serves as a cover sheet identifying the employer, plan, and data submission. Completing the P2 file is straightforward by following the instructions.

Note, D2 through D8 templates should have all been submitted for the employer by their carrier/TPA. However, the employer should confirm with the carrier/TPA.

Step Five: Once CMS grants access to the HIOS portal, the employer can submit the files. The submission deadline is June 1 every year, even if that falls on a weekend.

Employers have the option of having a third-party vendor assist in the submission process for a fee.

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Sarah Borders

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.

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