Skip to main content

As the situation in Ukraine evolves, businesses should be mindful of potential risks to their people, assets, operations, or supply chains in the region and globally. Marsh, as part of the Marsh McLennan family of companies, has created a page with information, tools, and resources related to the Russia-Ukraine conflict. Please visit the page for the latest information.

March, 23 2024

MMA’s Guide to 2023 RxDC Reporting

Transparency requirement


The 2023 RxDC reporting is due on June 1, 2024. There is no current extension for this despite June 1st falling on a Saturday this year. Portions of this guide are generally relevant for all employers, but the full guide is most relevant for employers that may have to complete certain RxDC reporting themselves. This may occur if an employer is unable to fully delegate reporting to its insurers, TPAs, or other third party vendors. For example, an insurer or TPA may decline to incorporate certain data from one or more carved-out vendors, and the carved-out vendors may be unable or unwilling to report that data themselves.

Table of Contents

Part 1What’s New for 2023 RxDC Reporting – This includes an overview of new or revised information that may affect employers who have to complete certain reporting as well as cross-references to slides where we address this information in more detail.

Part 2: RxDC Reporting Overview – This is an overview of the purpose for RxDC reporting, which plans are subject to it, and the process to delegate reporting to insurers/TPAs/PBMs (including their data surveys).

Part 3: Employer Submission of Plan Information – This is a brief overview of the HIOS registration process, when an employer must register, and where to upload information.

Part 4: The P2 and D1 Files – This is a discussion of the P2 and D1 RxDC files and how to complete them, although it is not intended to address every possible question an individual may have. If an employer must report any plan information, the P2/D1 combination is the most likely scenario.

Part 5: The D2 File Now Controls Reporting Level – This is a brief overview of a rule change affecting whether an employer’s plan information must be reported as plan specific information for that employer or in the aggregate as part of the insurer/TPA/PBM’s corresponding book of business.

Download our guide for more information on 2023 RxDC reporting.