Just in the Nick of Time – Good Faith Relief for RxDC Reporting

Just in the Nick of Time – Good Faith Relief for RxDC Reporting

As a refresher, the RxDC Reporting mandate requires group health plans and group health insurers to submit prescription drug and health care spending reports to the Department of Labor, the Department of Health and Human Services, and the Internal Revenue Service (“the Departments”) on an annual basis. The first report reflecting the 2020 and 2021 reference (calendar) years was initially due on December 27, 2022.However, the Departments realized that plans and issuers were facing challenges as they attempted to comply with this initial due date. In response to those challenges, the Departments offer the following:

  • Deadline Extended. The Departments are offering a reporting grace period until January 31, 2023 and will not consider 2020 and 2021 data submissions out of compliance as long as a good faith submission is made on or before January 31, 2023.
  • Submissions by Email Available for Certain Plans. If a group health plan or the reporting entity is submitting only the plan list, premium and life-years data, and narrative response and is not submitting any other data, it may submit the file by email to [email protected] instead of submitting in HIOS. The submission must include the following: the plan list file, premium and life-years data (data file D1), and a narrative response. Each file should include the reference year of the submission, the plan list or data file type (e.g. P2, D1), and the name of the group health plan sponsor.
  • Aggregation Suspended. Generally, if multiple entities are filing the D1-D8 information the D1 and D3 through D8 information cannot be less granular than the D2 information. For the temporary relief, this requirement is suspended, and each entity can file with any level of granularity.

This good faith relief notwithstanding, the 2022 reference year information must be reported by June 1, 2023.


The information contained in this Benefit Beat is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations. This information is provided as general guidance and may be affected by changes in law or regulation. This information is not intended to replace or substitute for accounting or other professional advice. You must consult your own attorney or tax advisor for assistance in specific situations. This information is provided as-is, with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein.


Just in the Nick of Time – Good Faith Relief for RxDC Reportinghttps://www.cbiz.com/Portals/0/Images/RxDC Reporting.jpg?ver=hN-6N4XNYuc3Ez42rKzETg%3d%3dThe RxDC Reporting mandate requires group health plans and group health insurers to submit prescription drug and health care spending reports to the Departments on an annual basis. The first report reflecting the 2020 and 2021 reference (calendar) years was initially due on December 27, 2022. 2023-01-05T20:00:00-05:00The RxDC Reporting mandaterequires group health plans and group health insurers to submit prescriptiondrug and health care spending reports to the Departments on an annualbasis.  The first report reflecting the 2020 and 2021 reference (calendar)years was initially due on December 27, 2022.  Regulatory, Compliance, & LegislativeEmployee Benefits ComplianceNo