RxDC Reporting (Prescription Drug Data Collection)

RxDC is the annual report every employer health plan and insurer must file with the federal government about prescription drug and healthcare spending. It comes from Section 204 of the Consolidated Appropriations Act, 2021, and it is due June 1 each year for the prior calendar year. The filing lists the plan's enrollment and premiums, its total medical and pharmacy spending, its 50 most-prescribed drugs, its 50 costliest drugs, the 50 drugs with the biggest spending increases, and the rebates the plan received from manufacturers.

In practice the carrier, TPA, and PBM file most of the pieces on the plan's behalf, and the employer supplies a few numbers (headcount, premium splits) and confirms the filing. That division of labor is convenient and it is also where the plan sponsor should pay attention. The rebate section is the one place in federal law where the PBM has to put in writing how much manufacturer money came back for your plan's drugs. If you have never seen your plan's RxDC submission, ask for a copy; you are entitled to it. The government's purpose is a public report on drug price trends, and the first one, released in 2024, showed employer plans paid an average of about $1,100 per person per year on drugs before rebates.

The takeaway: treat the RxDC filing as a free annual audit. Compare the rebate number in it to the rebate number your PBM paid you, and ask about any gap.