Overview

As you may be aware, Title II (Transparency) of Division BB of the Consolidated Appropriations Act (CAA) 2021 (Pub. L. 116-260), establishes protections for consumers to promote transparency in health care costs and, particularly, prescription drug costs.  

Under Section 204 of the Transparency Title, Centers for Medicare & Medicaid Services (CMS) will be collecting certain prescription drug and health care spending data from the group health plans and health insurance issuers on an annual basis.  

Although the legal obligation to provide CMS with this data is not placed directly on pharmacy benefit managers (PBMs), Prime recognizes that our clients need us to supply the relevant prescription drug information.  

Why it matters

Prime will be submitting certain files directly to CMS on your behalf. Specifically, Prime will submit P1-P3 files and D3-D8 files, along with the required narrative responses, for any period during the 2025 calendar year that you were receiving PBM services from Prime.  

Prime is waiving all fees associated with the submission of the 2025 data files; however, we reserve the right to charge for the submission of these data files in future years.  

Supporting information  

Please reference the accompanied letter and FAQ document  for additional information.  

Next steps 
  
Prime will only submit Prime data and will not submit D1 or D2 files reflecting premium and medical data. If you were receiving PBM services from another vendor during the 2025 calendar year, please contact the vendor to coordinate submission of the required data files.  

Action required 
  
If you have questions or wish to submit the pharmacy information to CMS on your own, please email CAA204Compliance@PrimeTherapeutics.com  by March 13, 2026.