Health Net 2024 RxDC Reporting Update

As part of the No Surprises Act (NSA) under the Consolidated Appropriations Act, 2021 (CAA), health plans are required to submit prescription drug and health care spending data to the: 

• Department of Labor
• Health and Human Services
• Treasury
• Office of Personnel Management.

This prescription drug data submission, known as the RxDC report, is gathered by the Centers for Medicare and Medicaid Services (CMS).

Key reporting details

• The RxDC report is due each year – beginning December 27, 2022 (for reference years 2020 and 2021) – and by June 1 of each subsequent year.
• The 2024 RxDC report is due by June 1, 2025.

Note: This is for informational purposes only – no action is required.

What Health Net of California, Inc. (Health Net) is Doing

• Health Net successfully filed the 2023 RxDC report on behalf of employer groups before June 1, 2024.
• ​​​​​Health Net will meet all regulatory obligations for 2024 reporting due June 1, 2025.
• The Plan will not require any data from employer groups to complete Plan List (P2) and Data File (D1) submissions on behalf of clients.
• The Plan will not issue communications to members, groups regarding RxDC filing (confirmation of filing completion, compliance, etc.), as this is not a regulatory requirement.
• The Plan will not establish contracts with groups regarding RxDC reporting, as this is not required by regulations.
• Employer groups do not need to take any action or pay any fees to Health Net for this reporting.

More information – FAQ

• What will be submitted?
  • D1 – D8 files will be submitted.
• At the time of submitting D2, is the aggregate total reported under Health Net’s EIN
  • Yes.
• If D2 is submitted as an aggregate, are the rest of the submissions also aggregated?
  • Yes.
• Will Health Net submit a Narrative Response?
  • Yes.

If you have questions about this communication, please contact your Health Net Account Representative.