--- title: "RxDC Reporting Explained: 2026 Deadlines and Broker Responsibilities" description: "RxDC (Prescription Drug Data Collection) reporting is the annual federal filing required of group health plans. Here is what RxDC is, who must file, and what brokers need to know." url: https://unlockedcrm.ai/blog/rxdc-reporting-guide canonical: https://unlockedcrm.ai/blog/rxdc-reporting-guide category: "Compliance" published: 2026-05-14 updated: 2026-05-14 author: "Jacob Lock" source: unLocked CRM — AI CRM for insurance agents --- # RxDC Reporting Explained: 2026 Deadlines and Broker Responsibilities ## TL;DR RxDC (Prescription Drug Data Collection) is an annual federal report required of group health plans under CAA Section 204. The deadline is June 1 each year for the prior calendar year. Fully-insured carriers usually file on behalf of employers; self-funded employers are legally responsible. ## Key data points - RxDC reporting is due June 1 each year for the prior calendar year, covering plan enrollment, premium, top 50 drugs by spend and claims, top 25 drugs by spending growth, and prescription drug rebates. - Self-funded employers bear legal responsibility for RxDC filing even when the work is delegated to a TPA or PBM. **RxDC reporting** is one of the most overlooked compliance obligations in group health insurance. Brokers who do not understand RxDC risk exposing their group clients to penalties — and miss an opportunity to position themselves as the compliance authority. ## What Is RxDC Reporting? RxDC stands for **Prescription Drug Data Collection**. It is an annual data submission required of group health plans and health insurance issuers under Section 204 of the Consolidated Appropriations Act of 2021 (CAA). The filing is submitted to the Centers for Medicare & Medicaid Services (CMS) via the HIOS RxDC module and contains aggregated data about: - Plan enrollment - Premium and life-years - Top 50 drugs by spend - Top 50 drugs by claims - Top 25 drugs by spending growth - Rx rebates and other manufacturer payments Filings are due **June 1 each year** for the prior calendar year (reference year). ## Who Must File RxDC? | Plan Type | RxDC Required? | |---|---| | Fully-insured group health plans | Yes (carrier usually files) | | Self-funded group health plans | Yes (employer responsibility, often delegated) | | Individual market plans | Carrier files | | Medicare Advantage / Part D | No (separate CMS reporting) | | HRAs and ICHRAs | Generally no (not group health plans for RxDC purposes) | | Stand-alone dental/vision | No | For fully-insured plans, the carrier typically files on behalf of the employer. For self-funded plans, the employer is legally responsible — though most delegate to their TPA, PBM, or broker. ## RxDC File Sections A complete RxDC filing includes: | File | Contents | |---|---| | P2 | Plan information | | D1 | Enrollment, premium, life-years | | D2 | Spending by category | | D3 | Top 50 drugs by spending | | D4 | Top 50 drugs by claims | | D5 | Top 25 drugs by spending growth | | D6 | Rebates by therapeutic class | | D7 | Rebates for top 25 drugs | | D8 | Rebates by NDC | | Narrative | Plain-language summary of submission | Most data files are populated by the PBM and carrier; the plan sponsor (employer) must coordinate the submission and ensure all files reconcile. ## RxDC Penalties CMS has not yet finalized a penalty schedule, but the underlying CAA Section 204 statute permits enforcement up to **$100 per affected individual per day** for non-filing — mirroring other ERISA reporting penalties. ## What Brokers Should Know For group health brokers: 1. **Fully-insured plans** — confirm with the carrier annually that they are filing on behalf of your client 2. **Self-funded plans** — coordinate with the TPA, PBM, and stop-loss carrier on who is filing each section 3. **Document the delegation** — keep written confirmation of who is responsible for each file 4. **Calendar June 1** — even if the carrier files, the legal responsibility rests with the plan sponsor Brokers who proactively manage RxDC become indispensable to their group clients — particularly mid-market self-funded employers. ## How unLocked CRM Tracks RxDC unLocked CRM's group health workflow includes: - Annual RxDC compliance task automation (April reminder, May confirmation, June 1 deadline) - Document storage for filing confirmations and PBM data files - Employer-facing compliance dashboard showing RxDC status - Integration with TPA and PBM data feeds for self-funded clients ## FAQ ### undefined ### undefined ### undefined ### undefined ### undefined ## Related - https://unlockedcrm.ai/blog/ichra-compliance-guide - https://unlockedcrm.ai/blog/scope-of-appointment-explained - https://unlockedcrm.ai/blog/first-dollar-coverage-explained --- Source: [RxDC Reporting Explained: 2026 Deadlines and Broker Responsibilities](https://unlockedcrm.ai/blog/rxdc-reporting-guide) — unLocked CRM, the AI CRM built for insurance agents. Citation permitted with attribution and a link to https://unlockedcrm.ai/blog/rxdc-reporting-guide.