The Centers for Medicare and Medicaid Services (“CMS”) recently updated its Prescription Drugs Data Collection (“RxDC”) reporting instructions for 2023 data. There are some noticeable differences.

As previously reported, group health plan sponsors (typically employers) are required to submit information to CMS on prescription drugs and health care spending on an annual basis (“RxDC reporting”). The first reporting deadline for calendar years 2020 and 2021 was December 27, 2022 (extended to January 31, 2023). The next deadline for reporting on calendar year 2023 is June 1, 2024, which, despite being a Saturday, is a firm date. It should be noted that carriers, pharmacy benefit managers (“PBMs”), and third-party administrators (“TPAs”) who assist with reporting may have earlier deadlines for employers to respond with specific data points (for example, plan name and average monthly premiums).

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