Compliance FYI: RxDC Reporting Due June 1, 2025
The Centers for Medicare & Medicaid Services (CMS) recently released instructions for Prescription Drug Data Collection (RxDC) due June 1, 2025. This round of RxDC reporting is focused on data from the 2024 calendar year. There are no major changes to the instructions from the reporting that was due June 1, 2024.
Data gathered through RxDC is meant to identify the major drivers of increases in prescription drug and health care costs while also helping to understand how various prescription drug rebates impact premiums and out-of-pocket costs.
RxDC Employer Considerations
While the June 1 deadline to complete RxDC is still months away, some insurance carriers, third party administrators (TPA), and pharmacy benefit managers (PBM), have begun communicating to employers about their intended approach to RxDC and any required employer action. Employers should review those communications carefully.
Surveys from third-party submitters
Third parties such as insurance carriers, TPAs, and PBMs can submit the required data on behalf of an employer. However, these third parties often do not have all the information necessary to complete the entire submission. Some third-party submitters may reach out with their own surveys to collect the missing information. It is important that employers respond to any survey in a timely and accurate manner to ensure that the third-party submitter can make a complete and accurate submission on their behalf.
Importantly, not all insurance carriers, TPAs, and PBMs will submit the data on your behalf. Also be aware that missing a survey deadline can mean needing to complete a portion of RxDC yourself. Employers would be well served to confirm with their carrier, TPA, and/or PBM what they are submitting and what information the employer will need to submit themselves, if any.
HIOS account required
RxDC information will once again be submitted through the Health Insurance Oversight System (HIOS). Individuals who were required to submit RxDC data themselves in past years will be able to use the HIOS account they previously created.
If you were not required to submit information in HIOS previously, and must in 2025, you will need to create a HIOS account. Be aware that creating your HIOS account can take up to two weeks so it is advisable to start the process sooner, rather than waiting until just before the June 1 reporting deadline. Instructions for creating a HIOS account are available here. Once you have created a HIOS account, you can follow the HIOS RxDC User Guide to walk through the process of actually submitting the required information.
If a third party is submitting all the required information on your organization’s behalf, you do not need to create a HIOS account.
Key Takeaways:
Employers should verify with their insurance carrier, TPA, and/or PBM that those third parties will make the required RxDC submission on their behalf. If those third parties does not plan on submitting the required information, the employer, as the plan sponsor, is responsible for ensuring all the necessary information is submitted.
The information provided is a summary of laws and regulations relating to employee benefit plan compliance. This information should not be construed as legal advice. In all cases, employers should consult with their own legal counsel.
