Feb. 12, 2025
2024 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 (RxDC) Reporting to the Centers for Medicare & Medicaid Services for the 2024 reference year is June 1, 2025. As in previous years, Blue Cross and Blue Shield of Texas will work with Pharmacy Services Provider Prime Therapeutics® to help support BCBSTX group customers with this regulatory requirement.
The table below outlines our standard reporting approach for the 2024 data by funding type and carve-in/carve-out Pharmacy Benefit Manager.
Funding Type and PBM |
Approach for reporting 2024 data |
|
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 17. |
|
For groups with Prime Therapeutics as their Pharmacy Services Provider, 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.
Note: Per the CMS RxDC Instructions, group health plans submitting a D1 file must also submit their own P2 plan list. |
|
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.
Note: Per the CMS RxDC Instructions, reporting entities submitting a data file must also submit their own plan list file. |
|
BCBSTX will submit P2, D1 and D2 reporting. 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 17. The client should consult with their PBM for files D3-D8.
Note: Per the CMS RxDC Instructions, reporting entities submitting a data file must also submit their own plan list file. |
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 17 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) on or after March 17. 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 May 2. 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, 2025. 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 in January with information pertaining to this reporting cycle. This update included this year’s RxDC reporting instructions, which did not contain any significant changes from last year. 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.
Prime Therapeutics®, LLC is a separate company Blue Cross and Blue Shield of Texas contracts with to provide pharmacy solutions. BCBSTX, as well as several independent Blue Cross and Blue Shield Plans, has an ownership interest in Prime Therapeutics.
