Compliance Corner: Upcoming Carrier Deadlines for Prescription Drug (RxDC) Reporting
Insurance companies are sending out client surveys to collect information that is needed to complete government RxDC reporting on behalf of employers.
Please note that ARC Benefit Solutions is often not copied on these notices for you so if you need help or have questions, please reach out to your ARC representative.
The deadlines for clients who were covered by these insurers as of December 31, 2025:
| CARRIER | REQUEST SENT TO CLIENT | DEADLINE |
| Aetna | Emails sent in February | March 31, 2025 |
| Anthem | Emails sent week of February 17 | March 19, 2025 |
| Humana | Using data from prior year | Not applicable |
| Medical Mutual of Ohio | Email week of February 27 | March 21, 2025 |
| United Healthcare | Complete in Employer Portal employereservices.com or unitedeservices.com | March 31, 2025 |
If carriers don’t receive this information from employers, the employers are then responsible for submitting the missing information personally to CMS. We know from past experience that this can be time consuming and difficult.
If the contact listed on your bill is not correct, it’s likely that you’re not receiving this email. Please let your ARC representative know.
What is the reporting requirement?
Under the Consolidated Appropriations Act of 2021, health insurers, fully insured, and self-funded group health plans are required to provide prescription drug and health spending data annually to the Departments of Health and Human Services, Labor, and Treasury via the Centers for Medicare and Medicaid Services (CMS). However, some of the information is not readily available to some insurers who handle the bulk of data reporting.
What information is requested?
These are the common data elements requested:
- Group health plan name. Very simply, this is a generic name that you might use to identify this on your taxes or financial statements. “ABC Company Group Health Plan” or “XYZ Inc. Group Medical Plan.”
- Plan number. If you have an existing 401(k) plan, you might already be familiar with this. It’s an arbitrary number assigned in case you ever need to file a 5500 that starts in a series such as 500, 501 502, etc. Groups with less than 100 employees are not required to file a 5500 due to a small group exemption.
- Plan sponsor/employer name and contact information. Hint: you are the plan sponsor.
- Plan sponsor/employer tax identification number (also called EIN or Employer Identification Number)
- Average monthly premium paid or percentage paid by employers versus employees.
For more information on the information requested by the government, please click here and review pages 30 to 34 of the CMS RxDC Report Instructions for more details.
If you would like help completing these forms, please connect with your ARC representative as we may need some additional information from you.
