The Consolidated Appropriations Act, 2021 (CAA) requires insurance companies and employer-based health plans to file periodic Prescription Drug Data Collection reports (RxDCs) with the Centers for Medicare and Medicaid Service (CMS). The purpose of this data is to allow government agencies to analyze American medical spending.

The first RxDC report, which is to contain 2020 and 2021 data, was originally due on December 27, 2022. The U.S. Departments of Health and Human Services, Department of Labor, and Treasury, issued a joint set of FAQs on December 23, 2022, which, in part, extended the deadline for the first RxDC report to January 31, 2023. Following this deadline, organizations must submit their RxDC reports annually, with the next deadline occurring in June 2023.

The FAQs also clarified a few other requirements for companies in preparing their RxDC reports. For example, companies with multiple health plans can issue multiple RxDC reports, one per health plan. Likewise, multiple stakeholders can issue a report for the same plan.

Finally, although organizations can include information in their RxDC reports about vaccines, they are not required to do so. Similarly, reporting data about amounts “not applied to the deductible or out-of-pocket maximum” is optional.

These RxDC reports provide certain data about prescription drugs relative to health plans, including the following:

  • General information regarding the plan or coverage;
  • The 50 most frequently dispensed brand prescription drugs;
  • The 50 most costly prescription drugs by total annual spending;
  • The 50 prescription drugs with the greatest increase in plan expenditures over the preceding plan year;
  • Total spending by the plan or coverage broken down by the type of costs;
  • Average monthly premiums paid by participants, beneficiaries, and enrollees and paid by employers;
  • Impact on premiums of rebates, fees, and any other remuneration paid by drug manufacturers to the plan or coverage or its administrators or service providers, including the amounts paid toward:
    • Each therapeutic class of drugs;
    • Each of the 25 drugs that yielded the highest amount of rebates; and
    • Other remuneration under the plan or coverage from drug manufacturers during the plan year.

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