RxDC — Prescription Drug Data Collection annual deadline
Every group health plan and health-insurance issuer reports prescription-drug and health-care-spending data to CMS by June 1 each year, covering the prior calendar year. Eight separate file specifications, plus a narrative response. Most fully-insured plans rely on the issuer; self-funded plans rely on a TPA or PBM, but the plan retains responsibility either way.
The deadline rule
CAA 2021 §204 established the RxDC reporting requirement. Each plan year, group health plans and issuers submit data covering the prior calendar year to the Departments (CMS, DOL, Treasury) via the CMS Health Insurance Oversight System (HIOS) RxDC module. The deadline is June 1 of every year, covering the calendar year that ended on the previous December 31.
The reporting requirement applies to almost every employer- sponsored group health plan that provides prescription-drug coverage. Grandfathered plans, account-based plans (HRAs, FSAs), excepted-benefit dental and vision, and stop-loss-only coverage are out of scope. Mid-market self-funded plans, fully-insured plans, and most carve-out arrangements are in scope.
The eight file specifications
The RxDC submission is structured around eight file types:
- D1 — Premium and life-years. Plan demographics and average enrollment.
- D2 — Spending by category. Total medical and prescription-drug spending broken out.
- D3 — Top 50 brand drugs by spending.
- D4 — Top 25 most-prescribed drugs.
- D5 — Top 25 drugs by total annual spending.
- D6 — Aggregated prescription-drug spending. Total Rx spending split between plan-paid and member-paid.
- D7 — Premium and life-years totals. Average premium per enrollee, employer/employee split.
- D8 — Prescription-drug rebates. Rebates, fees, and other remuneration received by the plan, issuer, TPA, or PBM from manufacturers.
Plus a narrative response (P2 file) answering qualitative questions about market segment, plan-year structure, and administrative items.
Carrier-vs-employer split — get it in writing
For fully-insured plans, the issuer typically files D1, D2, D6, D7, and D8. The plan or its TPA may file the rest. For self- funded plans, the TPA and PBM split the file responsibility, but the plan sponsor remains the responsible party if anything is missed.
The recurring failure mode: the carrier assumes the plan is handling D3/D4/D5; the plan assumes the carrier is. Confirm in writing — every year, before March — which party is filing each of the eight file types. If your contract doesn't address it explicitly, ask for a confirmation letter from the issuer.
Self-assessment — twelve items.
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Aggregated submissions
Carriers and TPAs commonly aggregate plans across multiple sponsors to file a single submission to CMS. This reduces submission volume but means the plan's individual data is combined with peers before reaching the Departments. The aggregation is permissible for most files but D7 (premium and life-years) requires plan-level segmentation in some cases.
For a sponsor managing fiduciary risk, aggregation is fine — the submission still satisfies the regulatory obligation. The risk is when a TPA aggregates a plan and the sponsor never sees the actual data submitted. Ask for a confirmation that your plan was included in this year's aggregated submission, with the submission ID.
What happens if a filing is missed
Unlike Form 5500, RxDC enforcement has been uneven. The Departments have taken a broadly enforcement-discretion posture for early submissions, but that posture is shrinking with each new annual cycle. As of 2026, late or missing RxDC submissions are within the Departments' enforcement scope and can carry civil-monetary-penalty exposure under PHSA §2723 (group market) or ERISA §502(c)(10).
The practical fiduciary risk is twofold: a missed RxDC submission surfaces in any DOL audit of the plan, and the underlying data (broker compensation, PBM rebates, plan-spending breakdowns) is information the fiduciary is responsible for understanding even if the carrier files on the plan's behalf.
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- CMS — Prescription Drug Data Collection (RxDC) — CMS landing page with current-year RxDC reporting instructions and submission portal.
- 45 CFR Part 149 Subpart D — Reporting on Pharmacy Benefits and Prescription Drug Costs — Federal regulation establishing the RxDC reporting requirement.
- Consolidated Appropriations Act 2021 §204 — Statutory basis for the prescription-drug data collection requirement.