Prescription Drug Data Collection (RxDC) Reporting for 2022

March 3, 2023

Prescription Drug Data Collection (RxDC) Reporting for 2022
Applies to all groups, ASO and fully insured

The deadline for Prescription Drug Data Collection (RxDC) Reporting to the Centers for Medicare & Medicaid Services (CMS) for the 2022 reference year is June 1, 2023. Blue Cross and Blue Shield of Texas (BCBSTX) will work with Pharmacy Benefit Manager (PBM) Prime Therapeutics^® to help support our group customers with this regulatory requirement.

The table below outlines BCBSTX’s standard reporting approach for the 2022 data by funding type and carve-in/carve-out PBM.

Funding Type and PBM	Approach for reporting 2022 data
Fully insured groups w/Prime as PBM Blue Balance Funded^SM groups Minimum premium plans	BCBSTX will submit the required plan list and data files for these groups. However, these groups will be responsible for providing BCBSTX with data on average monthly premiums. More information on this process will be shared via email at a later date.
ASO groups with Prime as PBM Cost Plus groups with Prime as PBM	For groups with Prime Therapeutics as their PBM, BCBSTX will work with Prime to submit the P2 plan list and D2 through D8 data files. All group customers will be responsible for submitting the D1 (Premium and Life Years) data directly to CMS through the RxDC module in the Health Insurance Oversight System (HIOS).
ASO groups with a carve-out PBM	BCBSTX will only submit the D2 data (spending by category) and P2 plan list (group health plan list) to the CMS site for ASO groups with a carved-out pharmacy benefit. ASO groups with a carve-out PBM will be responsible for all other required data that will need to be submitted to CMS through the RxDC module in HIOS by the group or their vendors.
Fully insured groups with a carve-out PBM	BCBSTX will submit P2, D1 and D2 reporting. The client should consult with their PBM for files D3-D8. However, fully insured groups with a carve-out PBM will be responsible for providing BCBSTX with data on average monthly premiums. More information on this process will be shared via email at a later date.

Fully Insured, Blue Balance Funded and Minimum Premium Groups
To submit the D1 file for these groups, BCBSTX will need to obtain the Average Monthly Premium data from the client. Groups will be notified via email solicitation soon and asked to submit the information through Blue Access for Employers^SM (BAE^SM). The data and attestation in BAE must be completed by April 13 to be included in our overall RxDC submission.

Additional information regarding our RxDC reporting will be shared as it becomes available. If you have questions, please contact your BCBSTX representative.

Prime Therapeutics LLC is a separate pharmacy benefit management company contracted by Blue Cross and Blue Shield of Texas (BCBSTX) to provide pharmacy benefit management and related other services. BCBSTX, as well as several independent Blue Cross and Blue Shield Plans, has an ownership interest in Prime Therapeutics.

This content reflects BCBSTX’s current approach to its reporting obligations pursuant to Section 204 of the Consolidated Appropriations Act, 2021. BCBSTX does not provide groups with legal or compliance advice. Group customers must contact their own legal or regulatory counsel if they have questions about these laws and regulations, what they require and how they will affect their group health plans.