RxDC Reporting 2026: What Employers Must Do

Under the Consolidated Appropriations Act, 2021 (CAA), group health plans and health insurers offering group or individual health insurance coverage must annually submit information about prescription drug and healthcare spending to the Center for Medicare and Medicaid Services (CMS). 

At the beginning of February, CMS released new instructions for the annually required prescription drug data collection (RxDC) reports due June 1, 2026. 

Prefer a quick overview? Watch our Employer Compliance IN FOCUS video for a concise breakdown of RxDC reporting requirements and what employers need to do before the June 1, 2026 deadline. 

RxDC Reporting Requirements and Data Submission Rules 

The instructions have an aggregation restriction preventing plans from submitting medical premium and life years data on D1 and pharmacy data on D3-D8 at a less “granular level” than D2 medical benefit data. Therefore, if D2 submissions are made at the plan level, D1 and D3-D8 must also be submitted at the plan level. Because most employers contract with multiple vendors, they will need to make sure that all plan data is included on their D2 form if all vendors do not agree to submit the data as part of an aggregated file. Because this D2 form data will be at the plan level, the aggregation rule dictates that D1 and D3-D8 data must also be at the plan level. 

Similar to prior RxDC reporting cycles, issuers, TPAs, Administrative Services Only Providers (ASOs), PBMs, or other third-party vendors may agree to submit RxDC Data on a plan’s behalf. Carriers/Issuers and other TPAs who agree to or plan to submit RxDC Data on their client’s behalf will need to collect certain information from Plans to facilitate their RxDC Reporting. 

Many carriers and TPAs have already notified plans of their process to collect such information by sending out “Request for Information” (“RFI”) letters to their clients. Within these notices, carriers and TPAs have imposed deadlines for plans to remit applicable information to them. 

Employers should be mindful of carrier and TPA imposed deadlines for remitting applicable information if they want the carrier/TPA to submit RxDC Data on the plan’s behalf. If a plan fails to comply with these deadlines, then the plan will be required to submit its RxDC Report on its own through CMS’s HIOS system by June 1, 2026. If you haven’t heard from your carriers and vendors, reach out to them regarding the upcoming June 1, 2026, RxDC reporting deadline. 

What Is the RxDC Reporting Deadline for 2026? 

The RxDC reporting deadline is June 1, 2026. Employers must ensure all required data is submitted either through their vendors or directly through CMS’s HIOS system if vendor deadlines are missed. 

RxDC 2026 Employer Action Steps 

Employers should not rely solely on vendors to manage this process. Clear ownership, coordination, and oversight are critical to ensuring complete and accurate submission. 

Action Items for Employers: 

1. “Look out” for these RFI letters or notices and/or 
2. Reach out to the applicable TPA and inquire about their process, if any, of performing RxDC reporting for their client 
3. If applicable, note TPA’s internal deadline to collect RxDC Data and provide information timely 
4. If you missed the carrier/TPA internal deadline, make sure to submit through CMS’s HIOS System by June 1, 2026 

Stay Ahead of RxDC Compliance 

RxDC reporting is just one example of how fragmented vendor processes can create compliance risk. 

Connect with a OneDigital Benefits Compliance Expert to ensure your reporting, vendor coordination, and data strategy are aligned and complete. 

For additional insights on employer-sponsored pharmacy benefits, explore our resource on GLP-1 drug coverage and employer strategy.