RxDC Drug Cost Reporting: A Practical Guide for Employers Filing in 2026

Every year, thousands of employer-sponsored health plans miss the RxDC filing deadline, not because they decided to ignore it, but because they assumed someone else was handling it. That assumption has quietly become one of the most common compliance gaps in group health plan administration, and it’s one the federal agencies are paying increasing attention to.

The Prescription Drug Data Collection (RxDC) reporting requirement, established under the Consolidated Appropriations Act of 2021 (CAA 2021), requires group health plans and health insurance issuers to submit detailed data on prescription drug and healthcare spending to the Departments of Labor, Health and Human Services, and Treasury. The data is used to produce an annual report to Congress on drug pricing trends, the impact of prescription drug costs on premiums, and the rebates flowing between manufacturers, pharmacy benefit managers (PBMs), and plans.

For plan years 2020 through 2022, the agencies provided transition relief that reduced filing burdens. That relief is gone.

Reporting for plan year 2025 data is due June 1, 2026, and the filing requirements are fully in effect. Here is what employers need to understand, prepare, and submit.

Why RxDC Exists — and What the Government Does With the Data

Before diving into mechanics, it’s worth understanding what this reporting requirement is actually designed to accomplish — because it shapes what data must be collected and why certain elements are mandatory even when they feel administratively burdensome.

CAA 2021 directed the Departments to collect plan-level data on prescription drug costs, premiums, and the rebate ecosystem in order to produce an annual public report on drug pricing and its effect on employer plan costs and employee premiums. The first report was released in 2023 and has since become a significant input for Congressional deliberations on pharmacy benefit reform, PBM regulation, and drug pricing legislation.

The data collected under RxDC is specifically designed to illuminate the gap between the list price of a drug and what a plan actually pays after rebates — and to track how much of that rebate value is passed through to the plan versus retained by the PBM. For employers negotiating PBM contracts, the regulatory framework around RxDC is directly connected to the broader push for PBM transparency.

Who Is Required to File

The RxDC reporting obligation applies to:

• Fully insured group health plans — the health insurance issuer files on behalf of the plan, but the plan sponsor (employer) remains responsible for ensuring that filing occurs
• Self-funded group health plans — the plan sponsor is responsible for filing, though the obligation is typically delegated to the TPA and/or PBM
• Level-funded plans — treated as self-funded for RxDC purposes; confirm with your TPA or carrier who is filing
• ERISA-governed plans — including medical, dental, and pharmacy-only plans that meet the definition of a group health plan

The following are exempt from RxDC reporting:

• Retiree-only plans
• Excepted benefits (standalone dental, vision, accident, or disability plans)
• Health Reimbursement Arrangements (HRAs) that are not integrated with a group health plan
• Plans with fewer than two participants who are current employees

If you are uncertain whether your plan is subject to RxDC, the default assumption for any ERISA-governed group health plan with active employee enrollment should be that it is. Confirm with your broker or ERISA counsel if there is genuine ambiguity.

What Must Be Reported: The Data Elements

RxDC reporting is submitted through the Centers for Medicare & Medicaid Services (CMS) Health Insurance Oversight System (HIOS) portal. The filing consists of eight data files, each covering a distinct category of information. Understanding what goes into each file is essential for knowing which vendors hold the data your plan needs to collect.

Plan-Level Files (D1 and D2)

D1 — Premium and Life-Year Data This file captures the plan’s average monthly premium, the employer’s share, and the number of covered life-years. For self-funded plans, the “premium equivalent” — the total per-member per-month cost of the plan — is used in place of an insurer-set premium.

D2 — Spending by Category This file breaks down total spending across six categories: hospital inpatient, hospital outpatient, professional services, clinical services, other, and prescription drugs. Pharmacy spending reported in D2 must reflect net spending after rebates — not gross spend before rebates. This distinction matters and creates coordination complexity with PBM reporting.

Prescription Drug Files (D3 through D8)

D3 — Top 50 Most Frequently Dispensed Brand Drugs Identifies the 50 brand-name drugs most frequently dispensed to plan members, by total number of claims. Does not require dollar amounts.

D4 — Top 50 Most Costly Brand Drugs Identifies the 50 brand-name drugs with the highest total plan spending (gross, before rebates), including the total annual spend and total dosage units dispensed.

D5 — Top 50 Drugs by Spending Increase Identifies the 50 drugs for which the plan’s total spending increased the most year-over-year, in absolute dollar terms.

D6 — Prescription Drug Rebates, Fees, and Other Remuneration This is the most complex and most consequential file in the RxDC submission. It requires reporting of:

• Total rebates received from drug manufacturers (or passed through by the PBM)
• Total fees paid to the PBM
• Other remuneration received in connection with the pharmacy benefit
• The portion of rebates applied to reduce premiums or premium equivalents

D6 is where PBM contract opacity has historically created the most compliance challenges. Employers on self-funded plans whose PBM contracts do not guarantee full rebate passthrough may struggle to obtain the data needed to complete D6 accurately. If your PBM contract does not require them to provide the data elements in D6, you have a contract problem that needs to be resolved at renewal.

D7 — Health Plan Administrative Expenses Reports total plan administrative costs, broken down by category: TPA fees, broker fees, wellness program costs, disease management program costs, and other administrative expenses.

D8 — Prescription Drug Administrative Expenses Reports administrative costs specific to pharmacy benefit management — including PBM administrative fees separate from drug costs and rebate arrangements.

Who Actually Submits the Filing — and What Employers Must Confirm

For most employers, the mechanics of RxDC submission are handled by vendors — but the compliance obligation remains with the plan. Here is how responsibility is typically divided:

Fully insured plans: Your health insurance carrier (Aetna, UnitedHealthcare, BCBS, Cigna, etc.) is responsible for submitting D1, D2, D3, D4, D5, and D6 on behalf of the plan. However, some D7 and D8 data elements — particularly broker fees and employer-paid administrative costs — may require data from the employer. Confirm with your carrier which elements they are filing on your behalf and which require employer input.

Self-funded plans: Your TPA typically handles D1 and D2 for medical and administrative data. Your PBM handles D3, D4, D5, and D6 for pharmacy data. D7 and D8 require coordination between the TPA, the employer, and potentially the broker. No single vendor has all the data — assembly requires active coordination.

The employer’s core obligation, regardless of plan structure:

• Confirm in writing that a vendor has agreed to file each required data element on the plan’s behalf
• Obtain the plan’s unique reporting entity identifier (the HIOS ID or EIN used in the filing) and confirm it matches your plan’s identity in the submission
• Verify that the filing was actually submitted and obtain a confirmation from the vendor
• Retain documentation of the delegation, the filing, and the confirmation in your plan records

The most common reason employers are found non-compliant is not that they refused to file — it’s that they assumed a vendor was handling it without ever confirming that the vendor had the data, the agreement, and the HIOS account access to do so.

The 2026 Filing: Key Dates and Deadlines

Reporting period: Plan year 2025 data (calendar year plans: January 1 – December 31, 2025)

Filing deadline: June 1, 2026

Filing portal: CMS HIOS portal (hios.cms.gov) — filers need a registered HIOS account; vendors filing on behalf of a plan use their own accounts but must reference the plan’s identifying information

Reference year comparison: D5 (spending increase file) requires year-over-year comparison, so plans will also need 2024 data accessible for the 2026 filing

For non-calendar-year plans, the filing deadline is the last day of the sixth month following the end of the plan year. Confirm your specific deadline with your broker or TPA.

The Most Common RxDC Compliance Failures

Based on the filing history since RxDC took effect, these are the gaps most likely to create problems in the 2026 cycle:

1. No formal delegation agreement with vendors Many employers have never signed a document that explicitly assigns RxDC filing responsibility to their TPA, PBM, or carrier. A verbal understanding or past practice is not sufficient. Each vendor relationship that involves filing responsibility should have a written agreement — either in the administrative services agreement (ASA) or as a separate data use and reporting addendum.

2. PBM contracts that don’t require D6 data disclosure If your PBM contract does not require the PBM to provide rebate, fee, and remuneration data in the format required by D6, you cannot file D6 accurately. This is both a RxDC compliance problem and a broader PBM transparency problem. Raise this at your next PBM contract renewal — and review the current contract language now.

3. Mismatched plan identifiers RxDC submissions must use consistent plan identifying information across all files. Mismatches between the EIN, HIOS ID, or plan year dates reported by different vendors (TPA vs. PBM, for example) result in incomplete or rejected filings. Coordinate with all filing vendors to confirm they are using identical identifiers.

4. D7 and D8 data gaps Administrative expense reporting is often overlooked because employers assume their TPA has all the data. In practice, D7 requires employer-paid costs — including broker fees, consultant fees, and wellness program costs — that the TPA may not have visibility into. The employer must provide this data or confirm it has been communicated to the filing vendor.

5. No filing confirmation obtained Employers who delegate filing to vendors but never request confirmation of submission have no way to know whether the filing was completed. A delegation agreement without a confirmation requirement is incomplete. Build a requirement for written filing confirmation — including the submission date and confirmation number — into every vendor delegation arrangement.

6. Assuming last year’s vendor arrangement still applies If you changed TPAs, PBMs, or carriers during 2025, the prior vendor may hold data for part of the year and the new vendor for the remainder. Mid-year transitions require explicit coordination to ensure the full plan year is covered in the filing. This is one of the most frequently missed scenarios.

Practical Action Plan for Employers: What to Do Now

Step 1: Confirm your plan’s filing status Determine whether your plan is subject to RxDC (almost certainly yes for any active ERISA group health plan) and identify which filing arrangement applies — fully insured, self-funded, or level-funded.

Step 2: Identify your filing vendors For each data file (D1 through D8), identify which vendor holds the required data and which vendor is responsible for filing. Document this in a filing matrix.

Step 3: Confirm written delegation agreements are in place Review your ASA, PBM contract, and carrier agreement to confirm that filing responsibility is explicitly assigned. If it is not, add a data reporting addendum before the filing deadline.

Step 4: Audit your PBM contract for D6 data access Confirm that your PBM contract requires the PBM to provide all rebate, fee, and remuneration data needed to complete D6. If it does not, address this at your next contract renewal and determine how to obtain the data for the current filing.

Step 5: Coordinate plan identifiers across vendors Confirm with your TPA and PBM that they are using the same EIN, HIOS ID, and plan year dates in their respective filing submissions.

Step 6: Provide D7 and D8 employer-held data Compile broker fees, consultant fees, wellness program costs, and other employer-paid administrative expenses and provide them to your TPA or filing vendor well in advance of the June 1 deadline.

Step 7: Set a confirmation deadline of May 15 Build in two weeks of buffer before the June 1 deadline. Require written filing confirmation from all vendors by May 15, 2026, so you have time to address any gaps or errors before the regulatory deadline.

Step 8: Retain all documentation Store the delegation agreements, vendor confirmations, and a copy of the filed data in your plan fiduciary records. This is your audit trail.

What Happens If You Don’t File

The CAA 2021 does not prescribe a specific per-day penalty for RxDC non-compliance in the same way that ACA reporting imposes per-form penalties. However, the Departments have authority to pursue enforcement under ERISA and applicable public health statutes, and continued non-compliance or patterns of non-filing create material enforcement risk.

More practically: the RxDC filing is one of several CAA 2021 transparency requirements that the DOL is actively monitoring. Plans with a pattern of non-compliance across multiple CAA transparency obligations — gag clause attestation, broker compensation disclosure, and RxDC — are more likely to draw targeted scrutiny than plans that can demonstrate consistent compliance.

Bottom Line

RxDC reporting is more complex than it looks on the surface — not because the filing itself is technically difficult, but because the data it requires sits across multiple vendors who may not have formal filing obligations in their current contracts and may not be coordinating with each other without active employer oversight.

The June 1, 2026 deadline is fixed. The data collection, vendor coordination, and delegation confirmation that must precede it take time. Employers who start that process now — by confirming vendor responsibilities, auditing PBM contract data access, and establishing a filing confirmation workflow — will file without incident. Those who assume it’s being handled will find out otherwise after the deadline has passed.

Taylor Benefits Insurance Agency helps self-funded, level-funded, and fully insured plan sponsors navigate RxDC reporting obligations, including vendor coordination, delegation agreements, and PBM contract review. Contact our team to confirm your plan’s filing readiness before the 2026 deadline.

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* This content is for informational purposes only and does not constitute legal or tax advice. Employers should consult qualified ERISA counsel and their benefits advisor to assess their specific RxDC reporting obligations and vendor arrangements.