2025 RxDC Filing Alert: Key Deadlines and Employer Responsibilities

The Centers for Medicare & Medicaid Services (CMS) has issued updated guidance for the 2025 Prescription Drug Data Collection (RxDC) reporting cycle. Notably, the latest instructions remain largely unchanged from the prior year.

Key Deadline

Plans must submit their 2025 RxDC data to CMS by June 1, 2026.

Vendor Coordination and Data Requests

Entities such as insurance carriers, third-party administrators (TPAs), pharmacy benefit managers (PBMs), and other service providers that support RxDC reporting typically distribute data requests or surveys to plan sponsors. These requests often have deadlines well ahead of the CMS filing date—commonly in March or April—so timely responses are essential.

In certain situations, particularly for self-funded plans with carved-out benefits, employers may be required to directly submit specific data files to CMS to complete the reporting process.

Background on RxDC Reporting

Group health plans and insurers providing group coverage must annually report prescription drug and healthcare spending data to CMS. This requirement is intended to improve transparency around drug pricing and its effect on premiums.

CMS is expected to publish a report twice a year using this data to highlight trends in prescription drug costs and their impact on healthcare expenses. However, such reports have not yet been released to date.

The RxDC submission includes:

  • A Plan List file (P2) for group health plans

  • Eight data files (D1–D8)

  • A narrative response

Not every file applies to all plans, and responsibilities for completing each component may vary depending on the plan’s structure and vendor arrangements.

Who Is Responsible for Filing?

Fully Insured Plans:
For plans without carve-outs, the insurance carrier typically handles the RxDC submission. Employers should confirm this responsibility in writing. If the carrier is contractually obligated to file, it assumes responsibility for compliance.

Self-Funded and Level-Funded Plans:
The employer (plan sponsor) holds ultimate responsibility. While TPAs, PBMs, or other vendors may assist with preparing and submitting data, liability for errors or noncompliance remains with the plan sponsor. It is critical to understand exactly what each vendor is handling.

Employer Action

  • Coordinate closely with carriers, TPAs, PBMs, and other partners to ensure accurate and timely submission of 2025 RxDC data.

  • Secure written confirmation from vendors who will file on the plan’s behalf and request proof of submission.

  • Respond promptly to all data requests from vendors to avoid delays.

  • Determine whether any portion of the reporting must be completed directly by the employer.

  • For example, employers offering self-funded plans with carved-out stop-loss coverage may need to submit specific files (such as P2 and D1) through CMS systems.

  • Verify whether a CMS HIOS account is already established. If not, initiate setup early, as account creation can take up to two weeks. Guidance is available through CMS user manuals and access resources.

Staying proactive and organized will help ensure compliance and avoid last-minute complications as the June deadline approaches.

Mark C