Feb. 28, 2024
2023 Prescription Drug Data Collection (RxDC) Group Reporting Approach
Applies to all groups
As part of annual reporting requirements from the No Surprises Act, the deadline for Prescription Drug Data Collection reporting to the Centers for Medicare & Medicaid Services for the 2023 reference year is June 1, 2024. As in previous years, Blue Cross and Blue Shield of Texas will work with Pharmacy Benefit Manager Prime Therapeutics® to help support our group customers with this regulatory requirement.
The table below outlines BCBSTX’s standard reporting approach for the 2023 data by funding type and carve-in/carve-out PBM.
Funding Type and PBM |
Approach for reporting 2023 data |
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BCBSTX will submit the required plan list and data files for these groups. However, we will need to obtain data on average monthly premiums from these groups. Details on this data collection will be sent via email to group contacts beginning the week of March 18. |
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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 need to submit the D1 (Premium and Life Years) data directly to CMS through the RxDC module in the Health Insurance Oversight System.* |
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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. All other required data will need to be submitted to CMS through the RxDC module in HIOS by the group or their vendors.* |
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BCBSTX will submit P2, D1 and D2 reporting. The client should consult with their PBM for files D3-D8.*
However, we will need to obtain data on average monthly premiums from these groups. Details on this data collection will be sent via email to group contacts beginning the week of March 18. |
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. Like last year, group contacts will receive an email solicitation beginning on Monday, March 18 requesting the necessary data be input into Blue Access for EmployersSM.
This data can be input into BAESM by the employer group or a broker (Primary Producer of Record or Delegated Producer with Maintenance Use) after March 18. Additional instruction will be available on the “Prescription Drug Data Collection” submission form within BAE.
The deadline for submitting this data to be included in our RxDC submission is April 26. Since CMS requires this data, any employer groups not included in BCBSTX’s submission will need to submit their own average monthly premium data directly to CMS by June 1, 2024. Groups should consult their own legal or regulatory counsel for any additional information on this requirement.
Additional Resources for All Group Customers
The CMS RxDC website 
was updated earlier this month with information pertaining to this reporting cycle. This update included new RxDC reporting instructions, which outline the most significant changes from last year’s reporting requirements. New file templates are also available for download from the site.
Additional information regarding our RxDC reporting will be shared as it becomes available. If you have questions, please contact your BCBSTX representative.
Blue Cross and Blue Shield of Texas contracts with Prime Therapeutics 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. MyPrime.com is an online resource offered by Prime Therapeutics.
*As a reminder, CMS requires any reporting entity submitting a data file to also include a plan list file with their submission.
