CAA 2022 Prescription Drug Data Collection (RxDC) Requirements For Health Plans – Due June 1st, 2023

The Consolidated Appropriations Act (CAA) Rx Data Collection (RxDC) component requires health plans/issuers to produce and file reports on prescription drug and health care spending for the 2022 calendar year by 6/1/2023. These reports are due annually and will be due by June 1st each year thereafter. The Centers for Medicare & Medicaid Services (CMS) has released a RxDC Reporting Instructions Guide to help facilitate reporting.

Carriers in the fully insured space are doing most, if not all, of the reporting for their group health plans. However, each carrier has a slightly different approach and may be contacting employers to confirm plan information, so it can be reported accurately. Review Word & Brown’s original Rx Data Collection column for full background on the reports due to CMS annually.

Part of the requirement is for plans to submit data regarding premium contributions, and many fully insured carriers are reaching out to their group clients to confirm specific contribution scenarios, so reporting can be facilitated accurately. While CMS is the collection agency for these plan and data files, enforcement for compliance falls upon the Department of Labor (DOL) and U.S. Department of Health and Human Services (HHS). Non-compliance penalties of $100/day may be issued by the Internal Revenue Service (IRS) for health plans that do not comply as required.

As of the publishing date of this column (March 24, 2023), the following information from our carrier partners outlines their processes regarding capturing accurate data, including any relevant deadlines, etc. The W&B Compliance Team expects added information to be released in the coming days and weeks. This column will be updated accordingly. Below is a breakdown on how the information is displayed for each carrier surveyed by the W&B Compliance team concerning the specified sections:

  1. Carrier Requirements:  Based on the information received from our carrier partners, “carrier requirements” lists information that employers will need to gather and send back to the carrier to help facilitate reporting on their behalf.
  2. Employer Survey:  This hyperlink provides direct access to the carrier survey/form that employers will use to provide information and data back to carrier partners.
  3. Who needs to report:  Based on the information received from our carrier partners, “who needs to report” lists who is required to complete the survey/form.
  4. Employer Identification Number (EIN): Some carriers are requiring employers to list EINs of other carrier plans sponsored, those EINs can be found below.
  5. Deadline:  Deadline is the last possible day an employer can submit the data over to carrier.
  6. Failure to meet deadline:  If an employer group fails to provide the required information back to the carrier by the specific deadline, how can they ensure they will remain compliant?
  7. Resources:  Provides hyperlinks to any relevant carrier information regarding requirements and press releases.


  • Carrier Requirements:
    • Total Premium Paid by Members.
    • Total Premium Paid by Employer.
    • Funding Arrangement.
    • Issuer Name & Legal Entity.
    • For CA HMO plans, the plan sponsor will submit a form for all their Aetna HMO plans under Aetna Health of California as their issuer/legal entity.
    • For non-HMO plans, the plan sponsor will submit a form for all CA OAMC/PPO plans under Aetna Life Insurance Company as their issuer/legal entity.
  • Employer Survey: Aetna RxDC Plan Sponsor Data Collection Form
  • Who needs to report: All Plan Sponsors must complete and submit this form separately for each product that Aetna underwrites or administers for the reference year. Update 3/23/2023: A plan sponsor will need to submit a form for each product based on Aetna’s legal entity. Aetna will retrieve the most current form(s) submission on 4/1/2023.
    • If a plan sponsor initially submits incorrect information, they can resubmit their form(s) with the updated information. Aetna will retrieve the most current form(s) submission on 4/1/2023.
  • Aetna Employer Identification Number (EIN): *Awaiting Carrier Response*
  • Deadline: 04/01/2023
  • Failure to meet deadline: We will submit the report without the required plan sponsor data.  Failure to respond will impact our ability to accurately report on the plan sponsor’s behalf, and Aetna will not be responsible for any liability associated with the inaccurate report. Please note, if your clients don’t complete this form, Aetna will submit on their behalf, but it will be incomplete. Per the RxDC regulations, your clients would then need to submit the information directly to CMS by 6/1/23.
  • Resources: Aetna RxDC Data Collection 

Anthem Blue Cross

Blue Shield of California

  • Carrier Requirements:
    • Basic group information such as group name, ID number, and physical business address ZIP Code.
    • Health care premium percentage paid by employer for Small Business Groups and Large Groups that have pharmacy benefits with Blue Shield, or,
    • Total health care premium paid by employer and employee, for Large Groups that have pharmacy benefits with another pharmacy carrier besides Blue Shield
    • Total Premium Equivalent Amount (for self-funded ASO only, when applicable) — Total cost of providing and maintaining coverage, including claims costs, administrative costs, Administrative Services Only (ASO) and other TPA fees, and stop-loss premiums.
  • Employer Survey: Blue Shield Healthcare Premium Contributions Employer Data Intake Form for D1 Report
  • Who needs to report: A survey submission is required for each unique group ID. Groups with both fully insured and self-funded plans should have different group ID numbers for each.
  • Blue Shield Employer Identification Number (EIN): 94-0360524
  • Deadline: 03/31/2023 at 6:00 p.m., Pacific
  • Failure to meet deadline: The group will be responsible for submitting their D1 data directly to CMS by the June 1, 2023, deadline.
  • Resources:


  • For clients with CalChoice, CalChoice will not be facilitating CAA RxDC reporting on behalf of their employer groups; CalChoice is only the administrator of the plan, not the carrier. Should the group have questions about filling out a specific carrier survey, groups are encouraged to reach out to the carrier directly, or CalChoice customer service at (800) 558-8003 for more guidance.

Health Net

  • Carrier Requirements: The Plan will not be requesting any information.
  • Employer Survey: N/A
  • Who needs to report: N/A
  • Health Net Employer Identification Number (EIN):
    • Health Net of California, LLC – 95-4402957
    • Health Net, Inc. – 95-4288333
  • Deadline: N/A, Health Net is assuming all reporting responsibilities.
  • Failure to meet deadline: *Awaiting Carrier Response*
  • Resources: The plan will not be issuing any communications to the groups/enrollees regarding this, since it is not required by the regulation.

Kaiser Permanente

Sharp Health Plan

  • Carrier Requirements: *Awaiting Carrier Response*
  • Employer Survey: *Awaiting Carrier Response*
  • Who needs to report: *Awaiting Carrier Response*
  • Sharp Health Plan Employer Identification Number (EIN): 33-0519730
  • Deadline: *Awaiting Carrier Response*
  • Failure to meet deadline: *Awaiting Carrier Response*
  • Resources: *Awaiting Carrier Response*

Sutter Health Plus

  • Carrier Requirements:
    • Company & Account Name.
    • Group Account ID.
    • Contribution type and totals.
  • Employer Survey: Sutter Health Plus Survey Link
  • Who needs to report: All employers.
  • Sutter Health Plus Employer Identification Number (EIN): *Awaiting Carrier Response*
  • Deadline: 03/01/2023
  • Failure to meet deadline: *Awaiting Carrier Response*
  • Resources: Sutter Health Plus Broker Announcement 


  • Carrier Requirements:
    • Member and employer average premium.
    • Self-funded administration fee/TPA fee (if applicable).
    • Medical, pharmacy, behavioral, wellness, stop loss vendors, and their Employee Identification Number (EIN) if a customer has coverage from vendors other than UnitedHealthcare.
  • Employer Survey: UHC RxDC Survey
  • Who needs to report: All Fully Insured and Level Funded, and self-funded (ASO), employers must complete the UnitedHealthcare survey.
  • UHC Employer Identification Number (EIN):
    • PPO: 36-2739571
    • HMO: 95-2931460
  • Deadline: 03/10/2023
    • Note that the UHC survey due date still says 03/03/2023; it was updated on 3/6/2023 to allow for more time.
  • Failure to meet deadline: If the customer does not give the data to UHC via the survey, it will be responsibility to submit the files to CMS for P2 and D1 themselves by June 1.
  • Resources:

Western Health Advantage

  • Carrier Requirements: Please review the GSA Cover Sheet provided at renewal to confirm contribution information. If updates are needed, please send corrections on the Cover Sheet to or contact your WHA Account Manager.
  • Employer Survey: N/A
  • Who needs to report: WHA will report employer and employee contributions based on employer’s contribution schedule as indicated on the most recent Group Service Agreement Cover Sheet.
  • Employer Identification Number (EIN): *Awaiting Carrier Response*
  • Deadline: There is no deadline. However, plans fully insured by Western Health Advantage may rely on the information WHA is submitting to CMS to comply with RxDC reporting requirements. However, by submitting the required reports, WHA is not agreeing to assume responsibility or liability for employer group health plans’ compliance with any other applicable laws.
  • Resources: WHA CAA RxDC Reporting Information


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