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

CareFirst will annually submit all RxDC files* on behalf of our fully insured clients and our self-insured clients that are not contracted under a Shared Processing Services Agreement or Network Lease Agreement. CareFirst will submit data for all applicable clients that contracted with us for any portion of the reference year.

*Certain client data will only be included on the D1 Premium and Life-Years file submission if any request for that data is provided by the deadline provided at the time of the request. In lieu of providing the data, clients will have an option to opt out of having CareFirst submit their D1 data.