RxDC Filing: Why Plan Sponsors Should Take a More Active Role

With the 2025 RxDC (Prescription Drug Data Collection) filing deadline approaching on June 1, 2026, it's a good opportunity to review the benefits of a plan sponsor filing its own RxDC reporting to CMS vs. having the PBM file on the plan's behalf in an aggregated manner.

The data you submit to CMS can help frame how well you understand the true drivers of your pharmacy trend. Instead of treating RxDC as a box-checking exercise farmed out entirely to TPAs and PBMs, this is an opportunity for plan sponsors to take a more active role in assembling and validating their own data—gaining visibility into unit costs, utilization patterns, and rebate flows that are usually buried in aggregate vendor reports. By leaning into the RxDC process, sponsors can meet the deadline and come away with a clearer, data-backed picture of their drug spend.

What RxDC filing is and why it exists

RxDC reporting was created by Section 204 of the Consolidated Appropriations Act, 2021, and requires group health plans and issuers to submit annual data on prescription drug and health care spending to federal agencies via CMS's RxDC module. The goal is to give the Departments of Labor, HHS, and Treasury enough information to identify major drivers of increases in prescription drug and health care costs, including the role of rebates and pricing trends.

The RxDC report includes multiple files: high-level plan and vendor information (P2), premium allocation and enrollment details (D1), and a series of data files (D2–D8) that capture medical and pharmacy claims, top drugs by frequency and cost, and rebate data. These templates require reporting of items such as total spending by category, the 50 most frequently dispensed drugs, the 50 most costly drugs, drugs with the greatest year-over-year expenditure increases, and the impact of manufacturer rebates on premiums and out-of-pocket costs.

Core compliance mechanics of RxDC

From a pure compliance standpoint, RxDC requires plans to report:

• General plan information, including plan year, enrollment counts, states of operation, and vendor identifiers.
• Premium and cost-sharing data, specifically the average monthly premium paid by employers and members and how premium dollars are allocated.
• Medical and pharmacy claims totals broken out by broad service categories and types of cost such as payments by plans, employers, and members.
• Prescription drug data, including top drugs by utilization and cost, and drugs with the largest increase in expenditures over the prior year.
• Rebate and other remuneration information, and how those amounts affect premiums and member out-of-pocket costs.

Reports are submitted electronically through CMS's Health Insurance Oversight System (HIOS) RxDC module, and the annual deadline has been June 1 for reporting on the prior year's coverage. While carriers and PBMs often prepare portions of the submission, employers sponsoring group health plans remain ultimately responsible for ensuring that RxDC reporting is completed accurately and on time.

Why plan sponsors should consider filing their own RxDC

Although many plan sponsors rely on their carriers, TPAs, or PBMs to perform RxDC reporting, taking a more direct role—up to and including filing your own RxDC data—creates distinct strategic advantages in understanding and managing drug spend.

Direct access to the underlying data

When a plan sponsor assembles P2 and D1, and coordinates or consolidates D2–D8, it gains a consolidated dataset that shows enrollment, premium flows, medical spend, pharmacy spend, and rebates at a plan level rather than only in vendor-aggregated form. Having that dataset internally allows the sponsor to slice spending by service category, product type, and funding arrangement in ways that standard carrier summary reports may not support.

Transparency into rebates and spread

Federal agencies have already identified that RxDC data at the PBM level can obscure how much of negotiated rebates are retained by PBMs versus passed through to plans. By controlling its own RxDC data mapping and reviewing rebate-related fields, the plan sponsor can begin to quantify the gap between total manufacturer remuneration reported and the amounts contractually guaranteed or actually credited to the plan.

Ability to validate vendor performance

Because RxDC requires consistency between premium, claims, and utilization data, it provides a framework for cross-checking vendor deliverables such as “top drug” lists, trend drivers, and estimated rebate guarantees. Sponsors using their own RxDC dataset can test whether the carrier's or PBM's narrative around trend aligns with the actual distribution of spend by drug, class, or channel reported to CMS.