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The No Surprises Act (NSA), enacted as part of the Consolidated Appropriations Act, 2021 (CAA), includes transparency provisions requiring group health plans to report information on prescription drugs and health care spending to the Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments). This requirement applies to group health plans and health insurance issuers in the individual and group markets but does not apply to account-based plans and excepted benefits. This reporting process is referred to as the “prescription drug data collection” (or “RxDC report”). The first RxDC report was due by Dec. 27, 2022 (covering data for 2020 and 2021); however, the Departments provided a submission grace period through Jan. 31, 2023, for this first report. Subsequent RxDC reports are due by June 1 each year, covering data for the previous calendar year. The deadline for the 2025 reference year report is June 1, 2026. According to interim final rules, employers may use issuers, third-party administrators (TPAs), pharmacy benefit managers (PBMs), or other third parties to submit the RxDC reports on their behalf. The Departments have stated that, although employers can submit these reports on their own, they expect it will be rare for employers to do so. Source: Zywave |
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RxDC Reporting Requirements Fully Insured, Level/Self-Funded Plans |
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Carrier |
Employer Responsibility |
Resources and Deadlines |
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Aetna |
The employer needs to complete the survey. The carrier will submit reporting. |
Aetna has issued email communication to the Plan Sponsor with a specific link to submit required information.
Deadline: March 31, 2026 |
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Allstate / Nationwide |
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Blue Cross and Blue Shield of Minnesota |
The employer needs to complete reporting. |
Groups (or brokers on the groups’ behalf) can complete reporting in the Connect portal.
Please see the notice linked below for instructions and key details:
Annual CMS Reporting & Access Management on Blue Cross Connect
Deadline: April 17, 2026 |
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Blue Cross and Blue Shield of Nebraska |
The carrier will handle all reporting. |
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HealthPartners |
The employer needs to complete the survey. The carrier will submit reporting. |
Employers with current HealthPartners coverage should log in to the Employer Portal to complete the RxDC survey.
Employers with terminated coverage will complete the survey via HealthPartners RxDC. This page contains a link to both the self-insured and fully insured versions of the survey.
Deadline: April 17, 2026 |
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Medica |
The employer needs to complete the survey. The carrier will submit reporting. |
All employer groups that had active coverage from Medica’s health plan at any time in 2025 need to complete this RxDC survey.
Deadline: March 10, 2026 |
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UHC |
The employer needs to complete the survey. The carrier will submit reporting. |
Complete the RxDC survey by accessing the RFI Tool located in the employer/broker portal.
To save time, it is recommended to use the UnitedHealthcare RxDC RFI Worksheet to gather required data in advance. Note: UHC is not accepting submission of the worksheet. Only electronic submission on the RFI tool is accepted.
UMR customers will receive a three question UMR RFI via email. It will not be available to complete online.
The deadline to answer the questions in the UHC RFI tool via the portal or emailed UMR RFI is March 31, 2026.
For training and additional information, view the resources linked below:
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If you have any questions, please contact our team via email at groupadmin@ociservices.com or give us a call us at (402) 330-8700.
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