Consolidated Appropriations Act Pharmacy Benefits and Costs Reporting (RxDC) Due June 1, 2026, for 2025 Data

Overview

The Consolidated Appropriations Act, 2021 (CAA) established protections for consumers related to surprise billing and transparency in health care. Prescription Drug and Health Care Spending Data Collection (RxDC) is one requirement within the CAA. The RxDC requires insurance companies and employer-based health plans to submit information about prescription drug and health care spending to the Departments of Health & Human Services, Labor, and the Treasury. The annual filing for the 2025 calendar year is due June 1, 2026.  This communication provides an overview of the requirement and MedCost’s support plan for this filing year (see MedCost Support section for details).

Who Must Submit?

Fully-insured plans, self-insured plans, and the Federal Employees Health Benefits (FEHB) Program are required to submit. Grandfathered status and ERISA status do not exempt a plan from this requirement. Medicare, Medicaid, Workers’ Compensation, and other excepted benefits are excluded.

Reporting Deadlines

The annual filing deadline is June 1 of the calendar year immediately following the reference year. The next RxDC report is due by June 1, 2026, and will cover data from January through December 2025.

Requirements

The RxDC requires a potential 12 files for submission that are segmented into plan lists, data files, and a narrative response.

A plan, issuer, or carrier can allow multiple reporting entities to submit on its behalf. For example, a self-funded group health plan may contract with a TPA to submit the Spending by Category data file (D2) and separately contract with a pharmacy benefit manager (PBM) to submit the Top 50 Most Costly Drugs file (D4).

MedCost Support

MedCost is prepared to provide the applicable elements above for our employer health plans. As the next due date for reporting approaches, we will be providing important updates on our support efforts such as any requests for updated information and submission confirmation. Please pay careful attention to those updates.

Employers Utilizing a MedCost PBM Contract

For Employers utilizing a MedCost PBM contract, MedCost will include in our reporting any required data that we house on behalf of our clients. This includes P2 and D1-D8, and any required narrative responses.

Employers Utilizing an External PBM Contract

Employers that have external PBM contracts will be responsible for coordinating with their PBM to ensure the production and filing of the D3-D8 pharmacy-specific reports.

As a result, MedCost will submit the following reporting for Employers with an external PBM contract:

• P2 – Group Health Plan List
• D1 – Premium and Life Years
• D2 – Spending by Category
• Narrative response specific to P2, D1 and D2 (PBM will be responsible for the Narrative associated with their D3-D8 files) 

Next Steps

Active Groups

MedCost will file the P2 plan list and D1 and D2 data files on behalf of all active groups. Once the submission is complete, we will provide a written confirmation for your records.

Terminated Groups

MedCost will file the Narrative, P2 plan list, and D1 and D2 data files of terminated clients for the applicable dates when MedCost administered the plan. Health plans that utilized the MedCost PBM contract will also have their pharmacy-specific D3-D8 data files filed on their behalf. Health plans that utilized a PBM contract outside of the MedCost PBM contract must reach out to their respective PBM to file the D3-D8 data files on their behalf or supply them to the current administrator to file. MedCost will not file these external PBM contract D3-D8 files.  

Please contact your MedCost Account Manager if you have any questions. If you wish to opt out of MedCost submitting on your behalf, please let your Account Manager know by May 1, 2026.