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, 2025. 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 2024 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, 2025, deadline.

If you had self-funded or level-funded coverage in 2024 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, 2025. 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, 2025, 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
  • Need to complete the necessary questions in the CAA Prescription Drug Data Collection (RxDC) RFI Tool located on the employer/broker portal (uhceservices.com, Employer eServices and All Savers)
  • UMR customers will receive a three question UMR request for information (RFI) as an email from their SAEs. It will not be available to complete online
  • It is important for you to complete the RFI by the March 31, 2025 deadline. To save time, we recommend using the UHC RxDC RFI worksheet to gather the required data in advance. Links to the worksheet are also in the RxDC Brainshark video and in the RxDC FAQs
• Blue Cross Blue Shield
  • Fully Insured, Blue Balance Funded and Minimum Premium Groups
    • Response due May 2, 2025
    • Group contacts will receive an email solicitation the week of March 17th requesting the necessary data be input into their online portal, Blue Access for Employers
  • ASO Groups with Prime
    • Responses due June 1, 2025
    • Plan sponsor must submit the D1 (Premium and Life Years) data directly to CMS through the Health Insurance Oversight System
• Aetna
  • Fully Insured and Level-Funded Groups\
  • Plan Sponsor Communication for RXDC reporting has been sent the week of January 27, 2025
  • Each plan sponsor (employer) will receive an EMAIL with a LINK to provide the required information
  • Deadline for Aetna to file RXDC reporting on behalf of the employer is March 31, 2025
•  SANA
  • Level-Funded Groups
  • Sana completes the reporting on the employers behalf and no additional information is requested
• Cigna
  • Cigna handles everything for fully insured and ASO clients.