Employers Who Treat RxDC As A Year-Round Tool Gain Leverage Over Rising Drug Spend

Employers often write off the RxDC reporting mandate as just another administrative hoop to jump through, assuming the obligation lies somewhere downstream. It doesn't. At its core, RxDC is a massive effort to pull back the curtain on what actually drives prescription drug costs, and it's the plan sponsor who ultimately holds the legal responsibility for putting all the pieces of data together even if vendors handle the actual filing.

Colbie DellaGrotta-Taylor, a Senior Employee Benefits Broker at Cross Insurance, understands why there's confusion. With more than a decade spent working at the intersection of benefits, payroll, and HR tech, she views the legislation not as an annual form, but as a data problem requiring serious coordination. She notes that the complexity of the filing has turned a simple reporting obligation into a high-stakes test of an employer’s vendor management and data infrastructure.

"Even though the carriers, the TPAs, and the PBMs often submit RxDC reports, the legal obligation ultimately sits with the plan sponsor," says DellaGrotta-Taylor. "If there's a mistake, it's the employer's responsibility." She says that reality catches many organizations off guard, particularly those that have treated the annual June 1 filing as a back-office task they can delegate and forget. But RxDC reporting carries real compliance risk, and the employers most exposed are often the ones who assumed someone else was handling it.

• An RxDC history lesson: The reporting requirement didn't emerge in a vacuum. For years, employers had limited visibility into how their healthcare dollars were being spent, especially in the small and mid-sized market. Rebates were opaque, drug pricing varied by contract, and the ability to compare across plans was virtually nonexistent. "Before this law went into effect, there was some transparency, but it wasn't consistent. Larger employers could negotiate access to certain reports, but that access was contract-dependent. It made it impossible to compare across plans," DellaGrotta-Taylor explains.

• Demystifying the spend: RxDC changed that by creating a single reporting framework that links manufacturer rebates, PBM economics, employer-paid premiums, and total healthcare spend. "For the first time, federal agencies can evaluate whether the math works the way the industry says it does. It's not just about drug transparency. It's about connecting all the pieces into one picture."

In DellaGrotta-Taylor's view, most employers underestimate what's involved in RxDC because they think of it as a single filing rather than a year-round governance process. "It's several submissions coming from different vendors," she clarifies. That's where a strong broker can be an asset, helping the employer map out the responsibilities, confirm who's filing what, and make sure the right documents are in place. "The most effective approach is proactive—understanding your plan structure, getting written confirmation from vendors, managing data requests early, and retaining proof of submission."

• Closing the data gap: The risk of fragmented coordination is real. Missing data is one of the most common causes of RxDC filing delays, and it often stems from basic infrastructure gaps like employers still relying on paper-based systems, EDI feeds that aren't configured properly, or simply not having a centralized place where benefits information lives. "Missing data shouldn't be an issue if you have everything streamlined, but employers aren't going to know what that looks like on their own. Let's say your industry is construction. You're focused on construction." She emphasizes that a knowledgeable broker sets an employer up for success through compliance, not just plan selection.

• Vetting your compliance: Even if you're happy with your current broker, she encourages asking pointed questions about what RxDC support systems are in place. "I always ask employers, 'What's your process? What tools does your broker have to keep you on track?' If you haven't received a penalty, it's easy for it to be out of sight, out of mind. But that doesn't mean the risk isn't there."

Beyond compliance, DellaGrotta-Taylor sees a strategic upside that most employers are leaving on the table. The data produced through RxDC reporting on things like rebate flows, utilization patterns, and cost drivers by therapeutic class is exactly the kind of information employers need to negotiate more effectively and control spend over time. But there's a caveat: the data should be used year-round, not just at the filing deadline. "That report alone shouldn't be why you're negotiating. It ties into budgeting and planning. You should be looking at that data continuously. If you're doing that throughout the year, there should be no surprises when renewal comes around," she says.

Ultimately, RxDC reporting was designed to enable a system where employers can see what's driving their premiums, hold PBMs and manufacturers accountable for how rebates flow back to the plan, and make informed decisions about their benefits strategy based on standardized, comparable data. The employers who treat the June 1 deadline as a window into how their healthcare dollars actually move will be the ones positioned to respond best in the face of unprecedented cost spikes. "These reportings are about holding manufacturers and PBMs accountable," DellaGrotta-Taylor says. "How much of those rebates are really going back to the employee? This is a chance to shine light on that, and I'm glad it's moving transparency forward."