RxDC Reporting: What Employers Need to Do Now

Employers of all sizes should be aware that while the 2025 RxDC (Prescription Drug Data Collection) reporting deadline of June 1, 2026, may seem far off, there is another impending deadline: Many carriers and third-party administrators (TPAs) are already imposing earlier internal deadlines. Employers who act now can avoid being caught off guard later this spring.

Why Employers Need to Pay Attention

While carriers and TPAs collect much of the data required for RxDC reporting, they generally do not have information about employer-collected payments, such as employee premium contributions or COBRA payments. As a result:

• Many carriers and TPAs will file D1 (Premium and Life Years) on the employers’ behalf, but ONLY if they receive the necessary data requested from employers by their internal deadline, some as early as March 2026.
• Some carriers and TPAs have announced they will not file this portion (File D1: Premium and Life Years) on the employers’ behalf.

Missing vendor deadlines means employers will have to take on the filing themselves, a process that involves registration and data preparation through CMS’s HIOS system.

Immediate Action Steps for Employers

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 the required information from the employer by their deadline. Employers can take the following steps toward this process:

• Confirm filing responsibilities. Reach out to your medical carrier or TPA now to determine whether they will submit File D1 for your plan.
• Understand internal deadlines. If your carrier or TPA requires employer data, note their submission deadline and respond promptly. Failure to do so will leave the employer responsible for filing.
• Prepare for self-filing if needed. Employers responsible for their own D1 will also need to submit File P2: Group Health Plan List, which serves as a cover sheet. To access the RxDC HIOS Module, create an account through the CMS Enterprise Portal by selecting the blue “New User Registration” button. Start this process early as account approvals and access setup can take time.

More Information

CMS provides detailed guidance and templates on its RxDC Resources Page, including instructions, example templates, and system manuals. If you need assistance confirming responsibilities or preparing data, contact your Hylant Toyotsu representative for personalized guidance. Don’t have one? Contact us here.

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