Compliance Alert | CMS RxDC Submission Required

To comply with the legislation to report on pharmacy information under the Consolidated Appropriations Act, you are required to submit premium information to the Centers for Medicare & Medicaid Services (CMS) by June 1, 2024. You should be receiving an email or an online portal alert to complete a survey or a RFI (request for information) from the vendors you had during the 2023 calendar year. You may need to proactively log into your prior vendor portal to access this request for completion. Your submission to these surveys and RFIs will allow the vendor to submit the RxDC submission on your behalf to CMS, by the June 1, 2024 deadline.

If you are self-funded or level-funded and do not submit this data by your carrier’s deadline, you will need to submit the premium information direct to CMS by June 1, 2024. To assist you in submitting direct to CMS, here is a guide for how to report the requested data, as well as a guide for registering for the portal to submit via the Health Insurance Oversight System (HIOS) application. You will not want to delay this as you do need to register your company in the process and there is an approval time of up to 3 days for this to be done before you are able to access the system to submit the premium data.  

Please note that we are being advised there is a potential penalty of $100 per employee for each day that you report past the June 1, 2024, deadline.

Please view the below details from the vendors who have posted information regarding this filing. If you do not see your vendor listed below, their information is pending. For further support, you can contact your Account Executive directly.

• UnitedHealthcare
  • Fully Insured, Level-Funded, and Self-Funded Groups
  • Response due by 4/10/24
  • Click here for more details on UnitedHealthcare’s data collection process
• Blue Cross Blue Shield
  • Fully Insured, Blue Balance Funded and Minimum Premium Groups
  • Response due by 4/26/24
  • Group contacts will receive an email solicitation beginning on Monday, March 18 requesting the necessary data be input into their online portal, Blue Access for Employers
• Aetna
  • Fully Insured and Level-Funded Groups
  • Response due by 4/12/24
  • Group contacts will receive an email starting on March 15 requesting the necessary data.
• Humana
  • Response due 4/1/24
  • Click here for access to Humana’s data collection form for self-funded groups
  • Click here for access to Humana’s data collection form for fully insured groups
• SANA
  • Level-Funded Groups
  • Sana completes the reporting on the employers behalf and no additional information is requested.   
• Cigna
  • Details pending

Read more on the background, updates for 2023 reporting and employer action items: HHS Releases Updated Drug Data Collection (RxDC) Reporting Instructions