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Compliance

RxDC Reporting: What Employers Need to Do Now

February 5, 2024

Employers of all sizes should be aware that while the 2023 RxDC reporting deadline may seem far away, there is another impending deadline – this one imposed by many carriers and TPAs – that relates to the upcoming 2023 RxDC reporting. Paying attention to this now may save employers a lot of work later this spring.

Since carriers and TPAs generally will not have information on how much an employer collected from members (including employee contributions, COBRA premium payments, etc.), some have announced they will not file that information on behalf of employers, leaving employers to file those data elements on their own.

Other carriers and TPAs may agree to file on behalf of employers, but only if they receive the needed information from an employer by a certain date—some as early as March 1—otherwise, those employers will also be responsible for filing those data elements on their own.

Immediate Steps for Employers

Employers should confirm with their medical carrier and/or TPA whether or not they will submit file D1: Premium and Life Years (D1) on their behalf. This is the file that contains the employer and member premium information.

We anticipate that most fully insured carriers – and some self-funded carriers and TPAs – will submit file D1 on behalf of employers, as long as they receive required information from the employer by their deadline. Many carriers and TPAs have already begun reaching out to employers to collect this data, and they are imposing hard and fast deadlines for responses. If employers do not submit information by the vendor’s deadline, the employer will likely be responsible for filing those data elements on their own.

Employers responsible for submitting their own D1 file will need to create an account on the Health Insurance Oversight System (HIOS) through the CMS website, as data is submitted through the RxDC HIOS Module. We recommend starting the process early if you know you will be responsible for submitting data. To create a HIOS account, visit the CMS.gov Enterprise Portal and click the blue “New User Registration” button.

How and When to File RxDC Data

The deadline to file RxDC reporting for 2023 is June 3, 2024 (as June 1 falls on a Saturday). Employers responsible for filing their own D1 file will also need to include file P2: Group Health Plan List (P2) as it acts as a “cover page” for the submission.

More Information

The CMS RxDC website includes multiple resources including reporting instructions, HIOS manuals and the RxDC templates. Reach out to your Hylant representative for further information.

The above information does not constitute advice. Always contact your employee benefits broker or trusted adviser for insurance-related questions.

Authored by

Holly Wahl Senior Vice President - Employee Benefits Compliance Leader


Holly Lam Compliance Advisor

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