The Consolidated Appropriations Act (CAA) requires that Group Health Plans report various information about their prescription drug costs and spending. The government calls the data submission of information on prescription drug costs and spending the “RxDC report.” The government will use the data to provide insight into increased spending on prescription drugs with reporting on rebates, total spending and PBM financials.

The reporting responsibility lies with the Group Health Plan sponsor, but TPAs and PBMs will have most of the information necessary to submit the required data on behalf of employer-sponsored plans. There are some data elements that neither your PBM nor Diversified Group would currently have in our systems, which will require some coordination with you to collect the necessary information.

The reporting deadlines are:

  • December 27, 2022 for 2020 and 2021 reference years calendar-year data (deadline moved to January 31, 2023)
  • All subsequent years are to be submitted annually by June 1st– next reporting deadline is June 1, 2023

Diversified Action:  Diversified Group will file on behalf of our clients the P2, D1 and D2 files along with the narrative file. The client’s PBM will submit files D3 through D8. Diversified successfully uploaded the RxDC Files P2, D1, D2 and narrative files on behalf of our clients prior to the initial deadline of 12/27. Submission numbers are: for 2020 – 1157 and for 2021 – 1197.

Diversified will be submitting the 2023 RxDC data file due June 1st, 2023 (for CY 2022 data) for our clients and former clients that we administered during CY 2022, provided we receive the required plan sponsor information concerning total annual contributions from the plan sponsor. Again, Diversified Group will file on behalf of our clients the P2, D1 and D2 files along with the narrative file, and the plan sponsor’s PBM will submit files D3 through D8.

The required information we need from clients again this year is the total annual employee contribution amount for the entire CY 2022.  In other words, the total amount of deductions taken from all employees over the course of the year rolled up into one total annual number. This is data that is required to be reported as part of the D1 file that we would not have access to and would need from the plan sponsors. A recent DocuSign went out to plan sponsors requesting this information for 2022.

Diversified Group will keep you updated on our progress and any changes in the ruling or process for 2023.

DG Compliance