The No Surprises Act (NSA), enacted as part of the Consolidated Appropriations Act, 2021 (CAA), includes transparency provisions requiring group health plans to report information on prescription drugs and health care spending to the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (Departments). This requirement applies to group health plans and health insurance issuers in the individual and group markets, but does not apply to account-based plans and excepted benefits.

This reporting process is referred to as the “prescription drug data collection” (or “RxDC report”). The first RxDC report was due by Dec. 27, 2022 (covering data for 2020 and 2021); however, the Departments provided a submission grace period through Jan. 31, 2023, for this first report. Subsequent RxDC reports are due by June each year, covering data for the previous calendar year.

Employers may use issuers, third-party administrators (TPAs), pharmacy benefit managers (PBMs), or other third parties to submit the RxDC reports on their behalf. The Departments have stated that, although employers can submit these reports on their own, they expect it will be rare for employers to do so.

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