Annual Notification of Section 204/CMS RxDC Reporting Practices

Curious how we are handling reporting for 2023? Read on for more information.

Thumbnail of Annual Notification of Section 204/CMS RxDC Reporting Practices

Per the requirements of the Consolidated Appropriations Act, 2021 (CAA) in Division BB, Title II, Part E, Section 204 of the CAA, 2021, “Required Reporting on Pharmacy Benefits and Drug Costs,” IPM will submit Section 204 Reporting for required plans no later than June 1, 2024.

Who does this impact?  Reporting is required for all health insurance issuers and fully-insured and self-funded group health plans, including grandfathered plans.

What timeframe is reported?  2023

When is the reporting deadline?  June 1, 2024

IPM will submit data for all impacted clients, active or termed, that had claims within the reporting period. IPM continues to provide this reporting free of charge to our clients. If you were an IPM client for only part of the reporting period, please contact your broker, third party administrator (TPA), or other PBM to ensure that data for those reporting periods will be submitted.

IPM will submit the following reports in aggregate on the client’s behalf:

  • P2 Group health plan list (with respect to D3-D8)
  • D3 Top 50 Most Frequent Brand Drugs
  • D4 Top 50 Most Costly Drugs
  • D5 Top 50 Drugs by Spending Increase
  • D6 RX Totals
  • D7 RX Rebates by Therapeutic Class
  • D8 RX Rebates for the Top 25 Drugs
  • Narrative response file specific to prescription data


While much of the data that must be submitted is related to the pharmacy benefit, some of it is not. Please contact your broker or TPA to ensure that the following reports are being filed on your behalf.

  • P2 Group health plan list (with respect to D1-D2)
  • D1 Premium and Life-Years
  • D2 Spending by Category
  • Narrative response file