Transparency provisions included in the No Surprises Act (NSA), enacted as part of the Consolidated Appropriations Act, 2021 (CAA) require reporting of information on prescription drugs and health care spending. This reporting is referred to as RxDC.
Annual reporting is due by June 1st each year for the prior calendar year’s data. This means that the next reporting deadline for RxDC is June 1, 2024 and will include 2023 data. There are several components of the data collection:
- P2: Employer-Based Health Plans (Plan Detail)
- D1: Premium & Life-Years data
- D2: Spending by Category data
- D3: Top 50 Most Frequent Brand Prescriptions data
- D4: Top 50 Most Costly Drugs data
- D5: Top 50 Drugs by Spending Increase data
- D6: Rx Totals data
- D7: Rx Rebates by Therapeutic Class data
- D8: Rx Rebates for Top 25 Drugs data
This reporting is ultimately the responsibility of the employer; however, many carriers and TPAs agreed to assist but only if they received the necessary information from the employer by a certain date. Information for D2 through D8 is generally submitted by the insurance carrier, TPA or PBM. However, P2 and D1 contain data points that require input from the employer group. Most of the information needed from the employer group is minimal but if you miss the carrier submission deadline, you will need to submit this information by other means.
Employers whose carriers/TPAs did not file on their behalf will need to submit their own reporting through the CMS HIOS website which requires new user registration. The CMS RxDC website includes important resources and instructions. In general, the information the employer groups are directly responsible for is:
- Total Premium paid by members for the reference year (2023)
- Total Premium paid by employer for the reference year (2023)
- Funding Arrangement(s) during the reference year (2023)
- Issuer Name/Legal Entity/Plan Number
Kristin Young, JD, PHR, SHRM-CP | Operations and Compliance Manager
