Employers offering an ICHRA are not required to complete RxDC (Prescription Drug Data Collection) reporting because ICHRAs are considered account-based health plans, which are exempt from RxDC filing requirements.
Do employers offering an ICHRA have RxDC reporting requirements?
No. Employers that offer an ICHRA do not have RxDC reporting obligations.
RxDC requirements apply to group health plans and insurance issuers, but account-based plans like HRAs (including ICHRAs and QSEHRAs) are excluded from reporting requirements.
Why is ICHRA exempt from RxDC reporting?
ICHRA is exempt because it is an account-based arrangement, not a traditional group health plan.
Under federal guidance:
RxDC reporting applies to group health coverage and issuers
Account-based plans (like HRAs) are excluded
ICHRA reimbursements are administered by the employer but are not a group health insurance plan
Because employees purchase individual health insurance coverage, the reporting responsibility shifts to the insurance issuers—not the employer.
Who reports prescription drug data for employees enrolled in an ICHRA?
The employee’s health insurance carrier is responsible for reporting.
Specifically:
Insurance issuers submit RxDC data for individual market plans
Employers do not submit prescription drug utilization data for ICHRA participants
Each carrier reports aggregated data directly to CMS
This applies even though the employer funds the ICHRA reimbursement.
Does QSEHRA have RxDC reporting requirements?
No. QSEHRA is also an account-based health plan and is excluded from RxDC reporting requirements for the same reason as ICHRA.
Employers offering either:
QSEHRA
ICHRA
are not responsible for submitting RxDC reports.
Do employers need to collect prescription drug data for ICHRA employees?
No. Employers are not required to:
Track employee prescription drug usage
Collect claims-level health data
Report pharmacy utilization or spending
Submit CMS RxDC templates
All prescription drug data collection is handled by insurers and pharmacy benefit managers (PBMs), not HRA employers.
Does offering an ICHRA create any additional ACA reporting obligations?
No additional RxDC-specific obligations are created by offering an ICHRA.
However, employers may still need to complete standard ACA reporting depending on size:
Small employers (<50 FTEs): Form 1094-B and 1095-B
ALEs (50+ FTEs): Form 1094-C and 1095-C
These are separate from RxDC reporting requirements.
What should employers offering an ICHRA do for compliance?
Employers should:
Confirm ICHRA plan is correctly classified as an account-based plan
Rely on insurance carriers for RxDC reporting (if applicable to individual plans)
Complete standard ACA reporting if required based on employer size
Retain documentation of ICHRA offering and employee participation
No RxDC submission or CMS portal reporting is required for ICHRA itself.
What if I’m being asked to complete RxDC reporting?
If you are an employer offering only an ICHRA and are asked to submit RxDC data:
You do not need to complete the submission
The requirement does not apply to account-based plans
You may direct questions to your insurance carrier or benefits administrator
The responsibility lies with insurance issuers, not the employer.