Updated Guidance from UHC/OXHP for CAA Prescription Drug Data Collection 

  • As a follow up to our previous communication below, UHC/OXHP has provided a PDF Flyer with additional guidance for brokers and employers regarding their 2023 Pharmacy Benefits and Costs Survey.
  • The PDF Flyer provides guidance on the minimum action that is required from employers (or their brokers) with UHC/OXHP to be in compliance with the CAA Prescription Drug Data Collection (RxDC) Reporting Requirement.
  • The PDF Flyer contains links by funding arrangement to a Worksheet with survey instructions and a live link that will take the employer (or broker) exactly where they need to go to complete the online survey. 

Click Here to download the PDF Flyer from UnitedHealthcare. 

 As a reminder, the deadline to complete the online survey is March 3, 2023.

As per UnitedHealthcare their approach on CAA prescription drug data collection (RxDC)  for all groups is changing for the June 1, 2023 submission of 2022 data to CMS. They have released broker and client communications, however clear direction has not been provided to date. We will continue to communicate as more information becomes available. 


What you need to know

  • UHC will have 2 approach options on CAA prescription drug data collection (RxDC) reporting; a Standard Approach (ASO, all level funded and fully insured groups) and an Alternative Approach (ASO groups only) 
  • The Standard Approach will require the group to complete a survey by March 3, 2023 which can be completed by either the group or the broker. UHC has released an online survey link to groups but unfortunately at this time is unable to provide a list of groups that received and/or completed the survey. Here is the survey link
  • UHC will submit all required data to CMS with the Standard Approach and there is no fee. The survey is the only required action the group needs to take. 
  • The Alternative Approach will allow the group to request the data and submit it themselves or use a TPA. This approach may incur a fee. 

Below is the information provided directly from UHC regarding this topic. 


CAA Background

Under the Consolidated Appropriations Act (CAA), health insurers offering group or individual health coverage and self-funded (ASO) 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). This information must be submitted to CMS by June 1, 2023, for 2022 data, through a web portal set up by the Centers for Medicare & Medicaid Services (CMS).


Below is a summary of UnitedHealthcare’s 2 approaches (standard and alternative) on CAA prescription drug data collection (RxDC) reporting.   


1) Standard approach (ASO, all level funded and fully insured groups)

  • Beginning with the June 1, 2023, reporting deadline, UnitedHealthcare will submit the P2 (group health plan), D1 (premium and life years), and D2 (spending by category) and the appropriate narratives for all customers with active coverage during the 2022 reference year.
    • For customers with OptumRx integrated PBM, UnitedHealthcare will also submit the D3-D8* files.
    • For customers that use any other PBM, including OptumRx Direct, the customer will need to work with that PBM to submit the D3-D8 files.
  • There is no fee for customers that use the standard approach

Important! Required customer survey for UnitedHealthcare standard approach 

  • To support our standard approach, UnitedHealthcare will need to collect additional data from each customer to complete the Rx data collection (RxDC) reporting.
  • To obtain the data, UnitedHealthcare released an online survey to all customers to collect the necessary data elements. To allow adequate time for UnitedHealthcare to create the required files, UnitedHealthcare must collect customer data and identify any outliers by March 3. Therefore March 3 is the survey submission deadline.
  • If the survey response is not completed by March 3, UnitedHealthcare will submit the data in its system on or before the June 1 reporting deadline. However, the submission may not be complete. Data elements not provided to UnitedHealthcare via the survey will need to be submitted to CMS by the group or another reporting entity, and the group accepts any risk arising from failure to provide any requested information to UnitedHealthcare for reporting.
  • All customers in-scope for our standard approach can complete the survey utilizing the following link: survey linkIf a customer did not receive a request to complete the online survey, they will still need to complete the survey to avoid any risk arising from failure to provide the requested information to UnitedHealthcare for reporting. The survey can be completed by the broker on a group’s behalf.

 At this time a Unitedhealthcare is are unable to provide a listing of customers that received and/or completed the online survey. 

2) Alternative approach (ASO only)

  • The customer may request its data from UnitedHealthcare and submit the data and appropriate narrative or engage a third party to submit the data for it.
    • Customers that use an outside Pharmacy Benefits Manager (PBM), including OptumRx Direct, must coordinate with the PBM to ensure all required data is submitted by the deadline.
  • A fee may apply for customers that use our alternative approach

Click on the links below for related materials and documentation