Group health plans and health insurance issuers must submit annual information on prescription drug and health care spending to the Centers for Medicare & Medicaid Services (CMS). This requirement is commonly referred to as the Prescription Drug Data Collection (RxDC) report. The next submission is due June 1, 2026, and will include data for the 2025 reference year.

• RxDC reporting is due June 1, 2026 (2025 reference year data)
• Multiple files are required; submission is only complete once all required files are received by CMS
• Confirm which vendor(s), issuer, TPA, and/or PBM will submit each file and whether the client must submit anything directly
• For self-funded and level plans, the employer remains ultimately responsible; encourage active tracking of vendor progress and timelines

Client Talking Points

Expect vendor requests for enrollment/premium details and respond promptly to avoid delays.

The RxDC report consists of multiple files. Some require plan-level information (for example, plan year start and end dates, enrollment, and premium data), while others require detailed medical and pharmacy benefit information. CMS has not made significant changes to the reporting instructions compared with the RxDC reporting completed in 2025.

Many employers rely on third parties, such as issuers, third-party administrators (TPAs), and pharmacy benefit managers (PBMs) to submit RxDC reports on behalf of their health plans. A single plan may use more than one vendor to complete the filing (for example, a self-funded or level funded employer may have its TPA and PBM submit different portions). A health plan’s submission is considered complete only when CMS receives all required files, regardless of which party submits them. As part of client support, confirm the filing approach and which vendor(s) will submit each required file.

Recommended Next Steps for Advisors

• Proactively remind clients that RxDC reporting is due June 1, 2026, and encourage them to begin coordinating with their issuers, TPAs, and/or PBMs (as applicable) to confirm who will submit the required RxDC files.
• Clients should also review their written vendor agreements to ensure RxDC reporting responsibilities are clearly addressed.
• Clients will likely need to provide vendors with plan-specific information (such as enrollment and premium data) to support the RxDC submission.
• Encourage clients to watch for vendor data requests and respond promptly.
• Because employers with self-funded and level funded plans remain ultimately responsible for RxDC reporting, advisors may also recommend that clients track their TPAs’ and PBMs’ progress to help ensure a timely and complete filing.

Resources

• CMS RxDC Website
• Amwins Benefits Compliance Library – RxDC Reporting Section

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