RxDC Reporting Deadlines
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. However, it’s not too early to start thinking about this reporting!
This reporting is ultimately the responsibility of the employer; however, many medical carriers and TPAs agree to assist but only if they receive the necessary information from the employer by a certain date. Data requested from employer includes information on employee premiums and average employee number. You should be on the lookout for any emails from your medical carrier requesting such information. Below are the deadlines and processes to submit the appropriate information for some carriers. Carriers have stated that if they don’t receive the requested information by their deadline they will not report on the employer’s behalf.
BCBST: Deadline February 5 – Carrier will report, but Groups must complete the ACA, MMSEA, CCA Employer Certification Survey
Bywater (Roundstone): Deadline February 28 – TPA will report, but Groups must complete the RxDC Election Form previously emailed to them.
UHC: Deadline March 31 – Carrier will report, but Groups must submit RFI Survey available on Employer Portal between February 1 and March 31, 2024.
Cigna: Carrier will report, no survey announced
Cigna + Oscar: Carrier will report, no survey announced
Employers whose carriers/TPAs do 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.
Deadlines to provide information are quickly approaching so don’t delay. While the regulation does not explicitly outline noncompliance penalties it is believed that ERISA Section 502 will apply which means that noncompliance penalties could be assessed at $100 per plan participant per day.
Kristin Young, JD, PHR, SHRM-CP | Operations and Compliance Manager
