By April Handlir, EHD Compliance Specialist
With the Prescription Drug Data Collection (RxDC) reporting deadline of June 1st fast approaching, it’s crucial to start your preparations sooner rather than later. The No Surprises Act (NSA), part of the Consolidated Appropriations Act (CAA), mandates health and prescription drug transparency for all ERISA group health plans. You may be wondering why this process was implemented? Simply put, the NSA aims to identify trends related to prescription drugs and their impact on out-of-pocket costs and total premium cost sharing for participants. The ultimate goal? Transparency.
This reporting process is another step in helping plan fiduciaries stay compliant. The legislation ensures that carriers, third-party administrators (TPAs), and pharmacy benefits managers (PBMs) adhere to these requirements, all in favor of the plan fiduciary.
Remember, the data is yours to access without delay, fees, gag clauses, or any other means of repressing plan details.
No matter the size or funding of your group health plan, submission is mandatory. For fully insured plans, the carrier takes the lead. For self-funded and level-funded plans, the responsibility falls on the employer. However, some carriers go above and beyond, submitting all files on behalf of their clients each year, regardless of funding. Rest assured that your EHD team is on top of tracking the carrier’s 2025 procedures for you. In the meantime, keep an eye on your email and mail for updates from your group health plan carrier. They will provide crucial submission dates and required details for the P2 (Group Health Plan List) and D1 (Premium and Life Years) files, which they might submit on your behalf. Most carriers will have a form for you to complete, requiring the P2 and D1 information between February and April for the June submission. If you miss the carrier’s deadline or if your carrier isn’t submitting these files for you, you’ll need to submit the P2 and D1 files yourself via the HIOS Portal Guide. If this is your first time accessing the HIOS system, make sure to leave enough time for setup.
As the fiduciary, you have the right to request granular data for your plan(s) D2-D8 (typically submitted by the carrier) and submit all files (P2 & D1-8) on your own. If you choose to do so, you’ll need to request the data early from the carrier and then submit it via the HIOS system. Generally, group health plans do not submit the carrier files (D2-D8).
The reporting is based on the prior calendar year regardless of your group health plan renewal. If your renewal is any month other than January, your submission will be on two lines—one for each plan year that occurs within the calendar year.
Begin by gathering the reporting details now so you do not miss out on the carrier submitting on your behalf. The CMS website houses more information, including the files and templates needed for submission.
P2 Required Data
- Group health plan name – ERISA Plan name found on your SPD
- Group health plan number – ERISA Plan number found on your SPD (501, 502, 503, etc.)
- Form 5500 plan number – ERISA Plan number found on your SPD (501, 502, 503, etc.) if you are over 100 covered participants
- States the plan(s) are offered in
- Marget Segment – small (under 50) or large (over 50) fully insured or small (under 50) or large (over 50) self-funded
- Plan year begin and end date
- Total of all enrollees (employee, spouse, children, domestic partners) as of 12/31/2024
- Federal Employer Identification Number (
D1 Required Data:
- The average monthly premium paid by the employees.
- The average monthly premium paid by the employer. The premium equivalents (claims costs, admin fees, stop-loss premium, network access fees, and payments made under capitation contracts) should be used for self-funded plans. You should not include stop-loss reimbursement, prescription drug rebates, or any cost associated with an FSA/HSA/HRA.
By remaining proactive, your fiduciary responsibilities for the RxDC reporting can be checked off the list for 2025!
