2025 Prescription Drug Data Collection (RxDC) Group Reporting Approach
Feb. 18, 2026
Applies to All Groups*
The Centers for Medicare & Medicaid Services requires Prescription Drug Data Collection (RxDC) reporting annually by June 1. As we have in past years, Blue Cross and Blue Shield of Illinois will work with Prime Therapeutics® to help support our group customers with reporting the 2025 reference year data, due June 1, 2026.
Action Required: Please share the appropriate information from the table below with your groups. This table outlines our standard reporting approach for the 2025 data.
Funding Type and Pharmacy Benefit Manager |
Approach for reporting 2025 data |
Fully Insured groups with Prime as Pharmacy Services Provider Blue Balance FundedSM groups Minimum Premium plans |
BCBSIL 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 to group contacts beginning the week of March 16. |
Self-Funded groups (including Collective Health) with Prime as Pharmacy Services Provider Cost Plus groups with Prime as Pharmacy Services Provider |
For groups with Prime Therapeutics as their Pharmacy Services Provider, BCBSIL 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. |
Self-Funded groups (including Collective Health) groups with a carve-out PBM |
BCBSIL 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. |
Fully Insured groups with a carve-out PBM |
BCBSIL 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 to group contacts beginning the week of March 16. 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 complete information in the D1 file for these groups, BCBSIL will need to obtain Average Monthly Premium data from the group. Group contacts will be sent an email solicitation beginning on Monday, March 16, requesting the necessary data be input into Blue Access for EmployersSM. To be included in our RxDC submission, this data must be submitted in BAESM by Monday, May 4.
This data can be input by the employer group or a broker (Primary Producer of Record or Delegated Producer with Maintenance Use). Since CMS requires this data, any employer groups not submitting data for our CMS filing will need to submit their own average monthly premium data directly to CMS by June 1, 2026. Groups should consult their own legal or regulatory counsel for any additional information on this requirement.
Resources for All Group Customers
CMS maintains an RxDC website with the latest guidance pertaining to this reporting cycle.
Additional information regarding our RxDC reporting will be shared as it becomes available. If you have questions, please contact your BCBSIL representative.
* This article, or a similar version, is being shared with employer groups in the Employer News newsletter or news alert.
Prime Therapeutics, LLC is a separate company Blue Cross and Blue Shield of Illinois contracts with to provide pharmacy solutions. BCBSIL, as well as several independent Blue Cross and Blue Shield Plans, has an ownership interest in Prime Therapeutics.