2026 UnitedHealthcare approach to CAA Prescription Drug Data Collection (RxDC) for reporting year 2025
The RFI opens Feb. 1, 2026. Customers must complete the RFI submission by March 31. 2026.
UnitedHealthcare approach and support
To support our customers with this important filing, UnitedHealthcare will be submitting the following June 1, 2026, for all employers who had active coverage during the 2025 reference year.
- P2 (Group Health Plan)
- D1 (Premium and Life Years) and
- D2 (Spending by Category)
- D3 to D8 for customers with integrated Optum Rx pharmacy. Customers who use any other PBM, including OptumRx Direct, must work with that PBM to submit the D3 to D8 files.
However, like last year, completion of the submission requires gathering some information not currently maintained in our system.
UnitedHealthcare will use a request for information (RFI) in the customer/broker portal to capture some P2 and D1 data elements not in our UnitedHealthcare systems. We are asking our employer group contacts to provide this information in the RFI by the deadline of March 31, 2026.
Note: UMR will send out an email from the UMR SAE to customers to respond to 3 questions. Customers with UHC (including Surest) and UMR will need to complete both the RFI and respond to UMR’s 3-question email as well.
UnitedHealthcare has prepared support resources to assist customers and brokers in providing information via the RFI. These resources include an RxDC information Brainshark video, a worksheet, external FAQs and an RxDC Guide. Look for the Prescription Drug Collection eblast that is going out by Feb. 2. The RFI link on the customer/broker portals will be available for data input on Feb. 1, 2026. If you do not receive the Pharmacy Benefits and Costs RxDC eblast email by Feb. 3, reach out and your UHC account representative will send you the information.
Customers must complete the RFI no later than March 31, 2026. This deadline is firm.
If the RFI is not completed and received by March 31, 2026, UnitedHealthcare will submit the data in our system to CMS on or before June 1, 2026.
- However, the submission will not be complete. Data elements that we requested but were 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.
Process for self-funded customers who plan to submit all their data to CMS
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, 2026. UnitedHealthcare data will be provided to the customers to complete their submission by mid-May.
This option is not available for fully insured or recommended for Level Funded customers.
Reference materials and support
- UnitedHealthcare RxDC Information Brainshark video – covers the approach for UHC and customers for reference year 2025 / submission year June 1, 2026
- Pharmacy Benefits and Costs RxDC Reporting Guide – summary of the RxDC CMS requirements
- Pharmacy Benefits and Costs RxDC FAQs
- UHC RxDC Worksheet
- CMS RxDC website
- Reporting instructions published by CMS: Prescription Drug Data Collection - RxDC - Reporting Instructions (cms.gov)
For questions, please contact your broker or your UnitedHealthcare representative.
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