Rebecca Tipton, SHRM-SCP

The RxDC, or Prescription Drug Data Collection, Report is a new ERISA requirement under the Consolidation Appropriations Act of 2021 designed to bring more transparency to healthcare costs. As it is a new compliance report and therefore unfamiliar to many, here are some important facts to help you ensure compliance for your organization.

What: The RxDC is a compliance report covering prescription drug benefit utilization by group health plans under the authority of DOL/ERISA and DHHS/CMS. The report requires eight data files to be submitted, which include information about plan premiums and prescription spending.

Who: Fully insured and self-funded group health plans are required to report, in addition to others, regardless of their size or number of employees. While typically, it will be the insurance provider/vendor who reports this information due to the detailed nature of the data being collected, the employer is ultimately responsible for ensuring compliance. Therefore, employers are advised to have their vendors verify, in writing, that the report has been submitted on the employer’s behalf and to ensure contractual measures are in place for non-compliance. This reporting requirement does not apply to health accounts, such as health savings accounts or flexible spending accounts.

When: The 2020 and 2021 calendar year information is due to be reported by December 27, 2022. However, the regular reporting date will be June 1 each year following the end of the corresponding calendar year. Therefore, the 2022 calendar year data will be due June 1, 2023.

Where: The required data files must be uploaded to the Health Insurance Oversight System (HIOS) RxDC module via access through the Enterprise portal, which is located here.

Additional Resources:

If you have any questions regarding this information, please reach out to your BMSS Professional and they can put you in contact with our HR Advisory consultant.

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