This filing applies to all employers of all sizes and all funding arrangements.
The next filing of the Consolidated Appropriations Act, 2021 (CAA) RxDC information is due June 1, 2024. Communications have been distributed by all insurance companies to assist with filing the necessary information. Each insurer has set different deadlines for data gathering. See below for list of carrier deadlines – note that some are approaching:
| Carrier/TPA (During 2023) | Data Collection | Carrier Links | Deadline |
| Aetna | Fully Insured/Level Funded/Self-Funded with integrated prescription: Aetna will submit all required reports on your behalf. Self-Funded with prescription carved out (direct PBM contract): Aetna will submit only medical portions of P2 and D1-D2. Plan Sponsors will need to work with PBM on D3-D8. Aetna is sending emails directly to employer groups. | N/A | April 12, 2024 |
| Capital Blue Cross | Fully insured and small business ASO groups need to file prescription drug data collection (RxDC) reporting for calendar year 2023. Large ASO groups who want Capital to submit files on their behalf should also complete the CAA reporting form. | None | TBD |
| Cigna | Clients must provide Cigna with information required for the 2024 reporting submission. This includes employer versus employee premium split, that is, the average employee versus employer percent of premium across the client’s medical, pharmacy, behavioral coverage (including Cigna and any non-Cigna coverage), corresponding to the population with Cigna coverage. REQUIRED: Please send an email to CAA204@Cigna.com by March 1st, 2024 with the following information: Client NameClient Account NumberAverage employee % of premiumAverage employer % of premium | CAA204@Cigna.com | March 1, 2024 |
| Harvard Pilgrim HealthCare | Tufts Health Plan | Point32Health needs assistance collecting monthly average premium information from each group customer in order to be fully compliant with the RxDC reporting requirements. As part of this effort, they are asking employer groups to complete a brief online survey with information for the 2023 calendar year. | Access to Surveys: Fully Insured Self-Insured | March 29, 2024 |
| HealthNow Administrative Services (HNAS) | Due to the complexity of reporting requirements and data required to complete the reporting, HNAS has partnered with Drug Cost Reporting to provide a vendor solution for our clients at a negotiated reduced fee. Additional information available. | Contact your account manager for the election form. | March 8, 2024 |
| Highmark Blue Shield | Fully Insured/Level Funded/Self-Funded with integrated prescription: Highmark will submit all required reports on your behalf. Self-Funded with prescription carved out (direct PBM contract): Highmark will submit only medical portions of P2 and D1-D2. Plan Sponsors will need to work with PBM on D3-D8. Highmark is sending emails with survey request directly to employer groups. | None | TBD |
| HMSA | Final submission guidance has not been provided. HMSA will assist in the filing of all fully insured and self-funded groups. A letter is expected to be sent to all employer groups on or around March 15, 2024 with instructions. | FAQs | TBD |
| Horizon BCBS | Fully Insured/Level Funded/Self-Funded with integrated prescription: Horizon will submit all required reports on your behalf. Self-Funded with prescription carved out (direct PBM contract): Horizon will submit only medical portions of P2 and D1-D2. Plan Sponsors will need to work with PBM on D3-D8. No other information available at this time. | None | TBD |
| Independence Administrators | No information has been released at this time. | TBD | TBD |
| Independence Blue Cross | No information has been released at this time. | TBD | TBD |
| Kaiser Permanente | Fully Insured/Level Funded/Self-Funded with integrated prescription: Horizon will submit all required reports on your behalf. On February 1, 2024, Kaiser sent a form via email to all contract signers requesting necessary information. | Prescription Drug Data Collection (RxDC) | CMS | TBD |
| Meritain | The Meritain Reporting team will be assisting with the filing again this year. A data request will be sent to plan sponsors by early March. No other information has been released. | None | TBD |
| United HealthCare — UMR — Surest | The Request for Information (RFI) tool opened for employers on Feb. 16, 2024. The deadline for employers to complete the RFI has been extended to April 10, 2024. UnitedHealthcare will submit the RxDC data by June 1, 2024. | UnitedHealthcare RxDC RFI worksheet UMR RxDC Survey worksheet Surest RxDC RFI worksheet | UHC/Surest: April 10, 2024 UMR: March 31, 2024 |
If you have not submitted your data or spoken with Birch about your submission, please connect with your account manager right away. The responsibility to submit the data falls on the employer but most of the data is being submitted by the insurance company, Third Party Administrator (TPA) or Prescription Benefit Manager (PBM). As a reminder, there are several components of the data collection:
- P2: Employer-Based Health Plans (Plan Detail)
- D1: Premium & Life-Years data
- D2: Spending by Category data
- D3: Top 50 Most Frequent Brand Prescriptions data
- D4: Top 50 Most Costly Drugs data
- D5: Top 50 Drugs by Spending Increase data
- D6: Rx Totals data
- D7: Rx Rebates by Therapeutic Class data
- D8: Rx Rebates for Top 25 Drugs data
Information for D2 through D8 are generally submitted by the insurance carrier, TPA or PBM. However, P2 and D1 contain data points that required input from the employer group. Most of the information needed from the employer group is minimal but if you miss the carrier submission deadline, you will need to submit this information by other means.
In general, the information the employer groups are directly responsible for is:
- Total Premium paid by members for the reference year (2023)
- Total Premium paid by employer for the reference year (2023)
- Funding Arrangement(s) during the reference year (2023)
- Issuer Name/Legal Entity/Plan Number