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RxDC Reporting for the 2023 Plan Year

Tuesday, February 06, 2024

Group health plans and health insurance issuers must annually submit detailed information on prescription drug and health care spending to the Centers for Medicare & Medicaid Services (CMS). This reporting is referred to as the “prescription drug data collection” (or “RxDC report”). The next RxDC report is due by Saturday, June 1, 2024, covering data for 2023.

Towne Benefits is gathering information from each of our carrier partners to help employers meet the RxDC reporting timelines. Please see below for the carrier/TPA deadlines and information.


Groups must respond to Aetna by April 12, 2024. In 2024, Aetna will require the following data from all plan sponsors:

    • Total premium paid by members for the reference year
    • Total premium paid by employer for the reference year
    • Funding Arrangement
    • Issuer Name/Legal Entity

If a self-insured plan sponsor requests to be excluded from Aetna’s D1 file, you do not need to complete this data collection process. Instead, plan sponsors should contact their account representative to request an exception.

What plan sponsors need to do:
Complete the fields provided in the emailed form no later than April 12, 2024. If any plan sponsor does not provide the requested data by 4/12, Aetna will submit the report without the required plan sponsor data. Failure to respond with complete and correct information will impact our ability to accurately report on the plan sponsor’s behalf, and Aetna will not be responsible for any liability associated with the inaccurate report. 


The next RxDC report is due by June 1, 2024. To meet the requirement, Anthem will follow the same process as last year and file on behalf of fully insured and ASO clients. This includes ASO groups who opt-in to the D1 reporting. In order to submit all required information and ensure reporting accuracy, Anthem will request some information from clients.

Here is a summary of the communications Anthem will send to Large Group, Small Group, and National Account clients and the actions they must take to complete their required RxDC filing.

The week of February 12 – Fully Insured clients

    • Anthem will email Fully Insured National Account, Large Group, and Small Group commercial clients, as well as clients with Minimum Premium, MEWA, and Anthem Balanced Funding plans. The email will include a link to an online form for these clients to provide the information we need to complete the filings on their behalf.

The week of February 12 – ASO client D1 opt-in

    • Anthem will email ASO Large Group and National Account clients and provide a link for them to request that we file their 2023 D1 Premium and Life Years report. For those who opt-in, we will submit the aggregated data by market segment on their behalf for the benefits we administer and maintain.

The week of June 3, 2024 -- Confirmation of RxDC filing

    • Anthem will email all Fully Insured and ASO commercial groups, including National Accounts, Large Group, and Small Group clients, to notify them that we have completed the required 2023 filing of prescription drug data on their behalf in compliance with federal regulations. This information will also be published to EmployerAccess Latest News.

For more information about the Consolidated Appropriations Act RxDC reporting requirements, please visit Anthem's CAA/Transparency Resource CenterCMS’ RxDC information page, or contact your Anthem representative.

Blue Cross Blue Shield of North Carolina

Blue Cross NC is actively working on the upcoming RxDC submission. Blue Cross NC will generate and submit identifying information and medical claims in the aggregate for all groups, with the exception of BlueTPA groups. Some of the data elements required are not available in Blue Cross and Blue Shield of North Carolina’s (Blue Cross NC) systems. To obtain the required information, Blue Cross NC will send an electronic survey to the group contact of record for groups with coverage at any time in 2023 (fully-insured and self-funded/ASO groups). 

    • The survey will be sent to groups on or by March 15, 2024. Alternatively, groups may access the survey via a website link that will be available soon.
    • If groups do not submit the data requested in the survey by April 15, 2024, Blue Cross NC will have no choice but to leave the required fields blank for those groups. Blue Cross NC will submit the data in its system to CMS; however, these groups’ data will not be complete without the required information gathered through the survey.
    • ASO Groups with a BlueTPASM Plan: BlueTPA ASO groups are responsible for filing with the regulatory agency. Neither Blue Cross NC nor Brighton Health Plan Solutions will file the RxDC on groups’ behalf. Blue Cross NC will supply a report with the medical data required for the filing by May 15, 2024. BlueTPA ASO groups must obtain the required pharmacy data from their pharmacy benefit manager or request that their PBM file on their behalf.   
    • Data elements not provided to Blue Cross NC by the survey response deadline will need to be submitted to CMS by the group or another reporting entity (i.e., another vendor or carrier). In other words, your group will need to submit D2 (and P2, as it is required for all submitters) directly to CMS through the HIOS platform by the regulatory deadline of June 1, 2024 to avoid any penalties. Failure to provide the requested information by April 15, 2024 will impact your Plan’s compliance with this mandate and will require direct submission by your Plan to CMS.
    • Employer groups are responsible for the accuracy and completeness of the information provided to Blue Cross NC through this process. The groups accept any risk arising from its failure to provide any requested information to Blue Cross NC for reporting.

Blue Cross Blue Shield of South Carolina

Groups must respond to BCBSSC's notice for information by April 1, 2024. Please click here for more information.


CareFirst intends to submit all RxDC files (P2, D1-D8) for both fully insured and self-insured clients. This requires them to collect certain information from each employer group that CareFirst serviced for any portion of 2023. Both the fully insured and self-insured markets require additional data elements, with certain nuanced complexities in the self-insured market.

CareFirst teams may be conducting outreach to assist in collecting this data and will provide more details in future communications.

Please click here for more information from CareFirst.


Please refer to Cigna's list of FAQs for more information.

Sentara Health Plans (Optima Health)

Sentara Health Plans is in the process of gathering the required data to meet the RxDC reporting timelines under the Consolidated Appropriations Act (CAA). They intend to file 2023 reference year data to CMS by the June 1, 2024, deadline on behalf of the following commercial group plans:

    • Fully Insured Small, Mid-Market, and Large groups
    • Self-Funded and BusinessEDGE® groups: if the group intends to file on their own behalf, please contact their Sentara Health Plans representative by February 23, 2024.

No action is required from the group or broker for the following commercial group plans; Fully Insured Small Group, Fully Insured Mid-Market, and BusinessEDGE.

To complete the filing for Fully Insured and Self-Funded Large groups, Sentara will require each group to supply additional information. These groups will receive an email with a link to complete an electronic form to collect the following data points:

    • Large Group Fully Insured
      • Average monthly percentage of premium paid by employee
      • Average monthly percentage of premium paid by employer
    • Large Group Self-Funded
      • Total monthly premium equivalent by plan by tier
      • Average monthly premium equivalent paid by employee
      • Average monthly premium equivalent paid by employer
      • Stop-loss premium if not administered by Sentara Health Plans

The form will be tailored to the group type and will only gather the required information needed to file the report on the group’s behalf. The deadline to submit the form is February 23, 2024.

More details on the regulations and requirements can be found on the CMS RxDC website. Sentara will also continue to update the frequently asked questions on their website as additional information becomes available.


UnitedHealthcare will relaunch the RFI on February 16, 2024 for clients with the extended completion deadline of April 10, 2024. The CMS instructions have resulted in changes to the calculation for member and employer premiums, as well as to the carve-out section on the worksheets.

Helpful links below:

Please note: If your company has an unbundled, self-funded plan and is using a TPA, please reach out to the TPA specifically for guidance.