Prescription Drug Data Collection (RxDC)

Under Section 204 of the Consolidated Appropriations Act (CAA) of 2021, health insurers offering group or individual health coverage and self-funded (ASO) group health plans are required to report data annually on prescription drugs and healthcare spending to the Departments of Health and Human Services (HHS), Labor (DOL) and Treasury (USDT).

The Centers for Medicare & Medicaid Services (CMS) within HHS is collecting Section 204 data submissions on behalf of the Departments and has published guidance and resources on their website at

The RxDC report consists of three different types of files – plan lists (or P files), data files (or D files), and a Narrative Response file. The P files are designed to act like a mapping tool for CMS to reconcile the data being reported in the D files. Any entity submitting a D file, must also submit the appropriate P file that indicates what plans are included in the population of data in the D file. The P2 is the only P file that is applicable to employer sponsored health plans.

Drug Collection Data
Plan Lists Data Files
P Stands for Plan
  1. P1 Individual and student market plan list
  2. P2 Group health plan list
  3. P3 FEHB plan list
D Stands for Data
  1. D1 Premium and Life-Years
  2. D2 Spending by Category
  3. D3 Top 50 Most Frequent Brand Drugs
  4. D4 Top 50 Most Costly Drugs
  5. D5 Top 50 Drugs by Spending Increase
  6. D6 Rx Totals
  7. D7 Rx Rebates by Therapeutic Class
  8. D8 Rx Rebates for the Top 25 Drugs

Fully Insured Groups

CareFirst will continue to file the RxDC reports on behalf of all fully insured groups for the data that we have. Fully insured groups (or another entity reporting on their behalf) will need to file a D1 report with the Average Monthly Premiums Paid by Members and Average Monthly Premiums Paid by Employers, and a corresponding P2 with certain group-specific demographic data.

View the instructions for fully insured groups.

Self-Insured Groups

CareFirst will continue to file the majority of the RxDC reports on behalf of self-insured groups for the benefits we administer. CareFirst will not file the D1 report for self-insured groups. It is the group’s responsibility to make sure that the D1 report and any reports for benefits administered by another vendor are completed and submitted directly to CMS.

View the instructions for self insured groups.