2024 UnitedHealthcare Approach to CAA Prescription Drug Data Collection (RxDC) Reporting

Under the Consolidated Appropriations Act (CAA), health insurers offering group or individual health coverage and self-funded group health plans are required to report data annually regarding prescription drugs and health care spending to the Departments of Health and Human Services, Labor, and Treasury (Tri-Agencies). June 1, 2024, is the required submission date to report 2023 data through a web portal set up by the Centers for Medicare & Medicaid Services (CMS).

To support our customers with this important filing, UnitedHealthcare will be submitting the P2 (Group Health Plan), D1 (Premium and Life Years) and D2 (Spending by Category) files for all employers who had active coverage during the reference year (2023). However, completion of the submission requires gathering some information not currently maintained in our system.

• UnitedHealthcare will also submit the D3-D8 data files for customers with OptumRx as an integrated PBM. UnitedHealthcare has access to all data required to complete the submission of D3-D8.
• Customers who use any other PBM, including OptumRx Direct, must work with that PBM to submit the D3-D8 files.

• UnitedHealthcare will collect P2/D1 data annually.

• We have created an RFI tool to capture required data.  
• To access the RFI tool, the employer must go to the employer portal beginning Feb. 14, 2024.
• The RFI must be completed by the April 10, 2024, deadline. 

• All UMR data will be collected via an emailed survey.
• A small group of non-integrated Surest employers may be required to complete information through a survey. Surest plan renewals between July 1, 2023, and Jan. 1, 2024, will use the RFI tool. Surest plan renewals between Feb. 1, 2024, and June 1, 2024, will use the survey.
• The survey was mailed the week of Feb. 1.
• The deadline for completion of the survey for UMR and non-integrated Surest employers is March 31, 2024.

• Some clients with business with UHC and or UMR/Surest may be required to complete both the RFI and the survey.
  • Dual customers who offer UHC/UMR, UHC/Surest or UMR/Surest may be required to submit the UMR data via an email survey and UHC/Surest data via the employer portal.
  • A small group of Surest customers may be required to complete an email survey if their renewals are between Feb. 1, 2024, and June 1, 2024.

• UnitedHealthcare has prepared an RxDC training video (Brainshark) for your use, to familiarize yourself with the RxDC requirements, RFI data collection process and resources.  

• Before completing the RFI or survey, customers may wish to use the Worksheet to gather required information, making the keying of data in the RFI or survey easier.
  • UHC RxDC RFI Worksheet
  • UMR RxDC Survey Worksheet
  • Surest RxDC Worksheet

Customers must complete the RFI no later than April 10, 2024. This deadline is firm. 

If the RFI is not completed and received by April 10, 2024, or survey is not completed and received by March 31, 2024, UnitedHealthcare will submit the limited data in our system to CMS on or before the June 1, 2024, due date. However, the submission will not be complete. Data elements not provided to UnitedHealthcare will need to be submitted to CMS by the health plan or another reporting entity. The health plan accepts any risk arising from the health plan’s failure to provide any requested information to UnitedHealthcare for reporting.

Self-funded customers wishing to have UnitedHealthcare provide data to them and who will take responsibility to submit all data to CMS themselves, must contact their UnitedHealthcare representative no later than March 31, 2024.

UnitedHealthcare will continue to monitor CMS if they issue new or updated instructions prior to the data submission.

For questions, please contact your broker or your UnitedHealthcare representative.

For reference:

• UnitedHealthcare RxDC Brainshark
• Pharmacy Benefits and Costs ASO Reporting Guide
• Pharmacy Benefits and Costs FAQs
• CMS RxDC website
• Reporting instructions published by CMS:  Prescription Drug Data Collection - RxDC - Reporting Instructions (cms.gov)