Consolidated Appropriations Act (CAA) RxDC Reporting Requirements

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 2024 reference year report is June 1, 2025.

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

For more information, read here.

RxDC Reporting Requirements

Fully Insured, Level/Self-Funded Plans

CARRIER

EMPLOYER RESPONSIBILITY

RESOURCES AND DEADLINES
Aetna The employer needs to complete the survey. The carrier will submit reporting.

Data Collection Requirement for RxDC Submission

Deadline: March 31, 2025
Allstate

To Be Determined – Not received from carrier

Find updates in the OCI News Center & weekly Producer Update email

To Be Determined – Not received from carrier

Find updates in the OCI News Center & weekly Producer Update email
Blue Cross and Blue Shield of Minnesota The employer needs to complete the survey. The carrier will submit reporting.

Complete the RxDC survey that was sent to groups from BCBSMN.

Deadline: April 4, 2025

For more information from BCBSMN, view the resource linked below:
Blue Cross and Blue Shield of Nebraska The carrier will handle all reporting.

BCBS Transparency Coverage Information

Click on “CAA Prescription Drug Data Collection (RxDC)” to learn more.
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.

RxDC Instructions

Deadline: April 15, 2025
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 2024 need to complete this RxDC survey.

Deadline: March 28, 2025
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.

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 or emailed UMR RFI is March 31, 2025.

For more information from UHC, view the resources linked below:

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.