As previously reported, plan sponsors of group health plans must submit information annually about prescription drugs and health care spending to the Centers for Medicare and Medicaid Services (“CMS”). The first deadline is December 27, 2022, for reporting on calendar years 2020 and 2021.


  • Employers with insured medical plans should enter into written agreements with their insurance carriers to transfer the reporting obligation and liability to the carrier.
  • Employers with self-funded plans should enter into written agreements with TPAs/PBMs to ensure the vendor will provide the required reporting to CMS. As the self-funded plan remains liable for reporting, employers should monitor the reporting efforts of the TPA or other third party to help minimize the exposure to liability for any reporting violation.
  • The next deadline for RxDC reporting is June 1, 2023 for 2022 calendar year.

To learn more, click here to download the document.

Have any questions regarding this notice? Please call your Total Benefit Solutions health insurance experts today at (215)355-2121.