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Each year, the federal Consolidated Appropriations Act (CAA) of 2021 requires health plans and insurance issuers to report prescription drug and health care spending information to the Centers for Medicare & Medicaid Services (CMS) through the Prescription Drug Data Collection (RxDC) process. These reports capture high-level data such as gross premiums, employer and employee contribution amounts, aggregate prescription drug spending for the applicable calendar year, and other related prescription drug disbursement data.

While fully insured carriers generally handle RxDC reporting on behalf of employer-sponsored plans, some level of employer input may be required to facilitate accurate reporting – particularly with respect to employer and employee contribution splits. The specific data-collection approach can vary by carrier. Some carriers rely on contribution information already on file, others collect this information during renewal, and others issue surveys or RFIs to verify contribution details before finalizing RxDC filings.

The information below summarizes how our carrier partners are facilitating RxDC reporting for the 2025 reference year (due June 1, 2026), including whether employer collaboration or RFI responses are required and any applicable response deadlines. Health insurance agents should review this information with their employer clients carefully, so they may respond to carrier requests as applicable. For a broader overview of RxDC reporting requirements and responsibilities, refer to the WB Compliance Wiki resource: CAA Pharmacy Data Collection (RxDC) Reporting.

This column will be updated as additional or outstanding carrier information becomes available and as reporting approaches or deadlines change.

Employer Contribution Surveys

Will you be sending surveys/RFIs to employer groups to verify employer vs. employee contribution amounts?
Yes – Aetna will email all Small Group plan sponsors beginning February 2, 2026, with instructions and a RxDC Plan Sponsor Data Collection Form.

What is the expected deadline for employer responses?
March 31, 2026

What happens if an employer does not respond by the deadline?
Aetna will submit the report, even if employer data is missing. Aetna will not be responsible for any liability associated with inaccurate reporting due to missing employer data.

Employer Communications

What type of communication will employers receive regarding RxDC surveys and deadlines?
Aetna will send an email on February 2, 2026, with instructions + a link to the RxDC Plan Sponsor Data Collection Form.

Confirmation of Filing

How can brokers & employers confirm that their RxDC files have been submitted on their behalf?
Pending additional information

Support & Contacts

What is the best contact or team for brokers and employers with RxDC questions about your process?
Contact your Aetna Representative
 

 (California)

Pending Anthem Blue Cross Response


 (Nevada)

Employer Contribution Surveys

Will you be sending surveys/RFIs to employer groups to verify employer vs. employee contribution amounts?
No – Anthem BCBS will not issue surveys this year. Instead, it will collect employer/employee contribution data internally at renewal (filing will be based on that renewal data). Small Groups and brokers have no action required for 2025 reporting. 

Anthem NV will file for all Small Group policies (ACA, AHP, ABF).

What is the expected deadline for employer responses?
N/A – Anthem is not collecting data via survey (contribution data will be captured during the renewal process).

What happens if an employer does not respond by the deadline?
N/A – no employer action is required.

Employer Communications

What type of communication will employers receive regarding RxDC surveys and deadlines?
More details are expected by the end of February 

Confirmation of Filing

How can brokers & employers confirm that their RxDC files have been submitted on their behalf?
Employers who want to review filing information must contact CMS directly.

Support & Contacts

What is the best contact or team for brokers and employers with RxDC questions about your process?
Employer/Broker Services Team: 833-389-1972
Large Group ASO: pamela.davidson@Anthem.com​​​​​​

Employer Contribution Surveys

Will you be sending surveys/RFIs to employer groups to verify employer vs. employee contribution amounts?
Yes – Blue Shield of California is collecting D1 Premium Contribution data through the Blue Shield Employer Connection Portal (for groups/brokers with access) and the Prescription Drug & Healthcare Spending Survey (for those without portal access).

What is the expected deadline for employer responses?
The expected submission deadline for employers is April 10, 2026. There is a window for updates only from April 10-19, 2026.

What happens if an employer does not respond by the deadline?
The group will not be included in Blue Shield’s filing, and the employer must report directly to CMS to avoid non-compliance.

Employer Communications

What type of communication will employers receive regarding RxDC surveys and deadlines?
Blue Shield will send follow-up emails to groups that have not completed the survey, reminding them to submit before the deadline.

Confirmation of Filing

How can brokers & employers confirm that their RxDC files have been submitted on their behalf?
Blue Shield will provide email confirmation to the submitter showing a record of responses submitted and a link to edit responses (until April 19).

Support & Contacts

What is the best contact or team for brokers and employers with RxDC questions about your process?
Blue Shield directs groups and brokers to contact their Blue Shield representative or use the Prescription Healthcare Spending Survey FAQs to answer any questions they may have.

Employer Contribution Surveys

Will you be sending surveys/RFIs to employer groups to verify employer vs. employee contribution amounts?
No – Cigna does not send annual surveys. Instead, it conducted a one-time collection of employer/employee contribution splits. Each year, employers verify or update this information during the renewal process.

What is the expected deadline for employer responses?
Contribution information must be updated by the end of March for the June 1 submission.

What happens if an employer does not respond by the deadline?
Cigna will use the existing data collected previously unless the employer opted out. If the employer opted out of Cigna filing on their behalf during the original collection phase, the employer is responsible for self-filing.

Employer Communications

What type of communication will employers receive regarding RxDC surveys and deadlines?
Employers are asked to verify/update contribution percentages during renewal. No separate RxDC survey will be sent. An email will be sent in June confirming that Cigna has submitted the required information on behalf of its clients.

Confirmation of Filing

How can brokers & employers confirm that their RxDC files have been submitted on their behalf?
Cigna will send a confirmation email once the RxDC filing is complete.

Support & Contacts

What is the best contact or team for brokers and employers with RxDC questions about your process?Contact your Cigna Account Executive if you have any questions. 

Employer Contribution Surveys

Will you be sending surveys/RFIs to employer groups to verify employer vs. employee contribution amounts?
No – Health Net will not require any data from employer groups to complete Plan List (P2) and Data File (D1) submissions on behalf of clients.

What is the expected deadline for employer responses?
N/A - No surveys will be sent

What happens if an employer does not respond by the deadline?
N/A – no employer action is required.

Employer Communications

What type of communication will employers receive regarding RxDC surveys and deadlines?
Health Net will not be issuing communications to members or groups regarding RxDC filings, confirmations.

Confirmation of Filing

How can brokers & employers confirm that their RxDC files have been submitted on their behalf?
Health Net will not be issuing communications to members or groups regarding RxDC filings, confirmations.

Support & Contacts

What is the best contact or team for brokers and employers with RxDC questions about your process?Reach out to your assigned Health Net Account Manager with any questions. 

Employer Contribution Surveys

Will you be sending surveys/RFIs to employer groups to verify employer vs. employee contribution amounts?
Yes – fully insured ER groups will need to complete the RxDC Survey form on Kaiser Permanente's employer portal. 

What is the expected deadline for employer responses?
Deadline: March 31st (Survey link available Feb. 1st to March 31st)

What happens if an employer does not respond by the deadline?
If an Employer group is unable to provide its premium contribution date via KP's survey by the last working day of March, it will need to submit their group's D1 & P2 files directly to CMS by the June 1 deadline.

Detailed reporting instructions, including templates for the various data files and other important information, can be found on the CMS RxDC Website.

Employer Communications

What type of communication will employers receive regarding RxDC surveys and deadlines?
Pending additional information

Confirmation of Filing

How can brokers & employers confirm that their RxDC files have been submitted on their behalf?
After the June 1st submission deadline, employer groups may reach out to their Account Manager to confirm the status of any RxDC reporting submissions to CMS.

Support & Contacts

What is the best contact or team for brokers and employers with RxDC questions about your process?Contact your KP Account Manager.

Pending Prominence Health Plan Response

Employer Contribution Surveys

Will you be sending surveys/RFIs to employer groups to verify employer vs. employee contribution amounts?
Yes, information will be requested. 

What is the expected deadline for employer responses?
Tentative deadline: April 17th. 

Email sent on March 17th will have the confirmed deadline. 


What happens if an employer does not respond by the deadline?
Employers will need to connect with CMS for assistance on what and how to file.

Employer Communications

What type of communication will employers receive regarding RxDC surveys and deadlines?
Email communications will be sent to brokers and employers.

Confirmation of Filing

How can brokers & employers confirm that their RxDC files have been submitted on their behalf?
If they submit the required form, they will be included in filing. An email confirming the filing has been completed will be sent.

Support & Contacts

What is the best contact or team for brokers and employers with RxDC questions about your process?Reach out to your dedicated Sharp Account Manager.
 

Employer Contribution Surveys

Will you be sending surveys/RFIs to employer groups to verify employer vs. employee contribution amounts?
Yes – email notices were sent to both brokers and employers on January 6, 2026, with a link to complete the online form.

What is the expected deadline for employer responses?
Preferred Deadline: March 1, 2026 
Final Deadline: May 10, 2026

What happens if an employer does not respond by the deadline?
If the employer is an ERISA group health plan, and does not provide the required premium information, the employer must submit its own P2 and D1 file directly to CMS.

Employer Communications

What type of communication will employers receive regarding RxDC surveys and deadlines?
Initial email will be sent January 6, 2026, to brokers and employers with the online form link. An additional follow-up email will be sent in February 2026.

Confirmation of Filing

How can brokers & employers confirm that their RxDC files have been submitted on their behalf?
N/A – Sutter Health Plan does not intend to announce when filing is complete, though it intends to complete the filing by June 1, 2026.

Support & Contacts

What is the best contact or team for brokers and employers with RxDC questions about your process?Customer Service: 855-315-5800 (Mon-Fri, 8 a.m. - 7p.m.)
SHP Service Team: SHPServiceTeam@sutterhealth.org

Employer Contribution Surveys

Will you be sending surveys/RFIs to employer groups to verify employer vs. employee contribution amounts?
Yes – via an online RFI tool. UHC/Surest customers will enter contribution data through the customer/broker portal. Customers with both UHC and Surest only complete one RFI and customers with both fully insured and ASO plans must complete two RFIs.

What is the expected deadline for employer responses?
March 31, 2026

What happens if an employer does not respond by the deadline?
UHC will submit only the data already in its systems, but the submission will be incomplete. Employers will be required to self-submit missing data directly to CMS by June 1.

Employer Communications

What type of communication will employers receive regarding RxDC surveys and deadlines?
UHC will notify brokers/consultants via the January 28 Connect eNewsletter. UHC/Surest customers will be notified via the January 29 Connect eNewsletter (or by Feb 1).

Confirmation of Filing

How can brokers & employers confirm that their RxDC files have been submitted on their behalf?
Customers and brokers can check real-time status and download completed responses in the portal. Brokers must be listed as the Agent of Record to access client data. Brokers may request a new report from their UHC Account representative showing: All employers for whom they are AOR/BOR and the status of each employer’s RFI.

Support & Contacts

What is the best contact or team for brokers and employers with RxDC questions about your process?For technical RFI issues, employers can email: caa_rxdc_tech_support@uhc.com.

For general questions, reach out to: clientserviceoperations@uhc.com or call 800-591-9911. 

Pending Western Health Advantage Response
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