Rose Street Advisors is honored to be recognized once again by the National Association of Plan Advisors (NAPA) as one of the nation’s Top Defined Contribution (DC) Advisor Teams. This marks our fourth consecutive year receiving this distinction, an achievement that reflects our continued commitment to delivering exceptional retirement plan guidance to employers and their employees.

Among the 373 teams recognized nationwide, only 21 are located in Michigan, and we are the only firm in Kalamazoo to earn a place on this year’s list. For us, this recognition is more than a milestone; it is a meaningful affirmation of the work we do every day to support organizations, strengthen retirement outcomes, and serve as a trusted partner to leadership teams and plan participants alike.

A Team Built on Purpose and Partnership

Our retirement plan advisory team, led by Scott Higgins, AIF®, CFP®, CPFA®, NSSA®, Financial Advisor, and supported by Julia Sanders, AIF®, CPFA®, Retirement Relationship Manager, brings a disciplined, service‑driven approach to every plan we support. Their work spans fiduciary guidance, plan design consultation, investment due diligence, and participant education, all delivered with a focus on clarity, responsiveness, and long‑term impact.

Within our firm, we often return to a guiding principle that shapes our culture and our client experience:

“What we do and how we do it matters.”

This mindset influences how we prepare for meetings, how we communicate complex topics, and how we support organizations navigating the evolving retirement landscape. It’s a reminder that technical expertise is essential, but the way we show up for clients is equally important.

Recognition That Reflects Real-World Impact

NAPA’s Top DC Advisor Teams list highlights firms with at least $100 million in defined contribution assets under advisement and recognizes teams that demonstrate leadership, consistency, and meaningful contributions to the private retirement system. Unlike broader industry rankings, this list focuses on the work of individual teams within a single physical location—making it a direct reflection of the service we provide to employers and participants in our region.

We are grateful for the trust our clients place in us and remain committed to helping organizations build stronger, more confident retirement futures for their employees.

2026 NAPA Top DC Advisor Teams, created by NAPA. Presented in March 2026 for the previous year. All NAPA members with over $100 million in defined contribution assets under advisement made the list. 372 Advisors were recognized. Advisors pay a fee to hold out marketing materials. Not indicative of advisor’s future performance. Your experience may vary. Click here for the most recent award information.

This material and the opinions voiced are for general information only and are not intended to provide specific advice or recommendations for any individual. To determine waht is appropriate for you, please contact me directly or consult another qualified professional

Securities and Investment Advisory Services Offered Through M Holdings Securities, Inc. A Registered Broker/Dealer and Investment Advisor, Member FINRA/SIPC. Rose Street Advisors is independently owned and operated. #5364245

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Understanding Full-Time Equivalents (FTEs) Under the Affordable Care Act (ACA): A Guide for Employers

What is a Full-Time Equivalent (FTE)?

A Full-Time Equivalent (FTE) is a unit of measurement that represents the workload of an employee in a way that makes workloads comparable across various employment structures.

Who Needs to Calculate FTEs?

Employers across various industries use FTE calculations for multiple purposes. The purpose focus here today is companies subject to the Affordable Care Act (ACA): To determine if they qualify as an applicable large employer (ALE), requiring them to offer health insurance to full-time employees.

FTEs and the Affordable Care Act (ACA)

Under the ACA, employers must determine if they qualify as an Applicable Large Employer (ALE). This includes assessing common ownership across multiple employers. An ALE is an employer with an average of 50 or more FTEs in the previous calendar year. ALEs are required to offer affordable health coverage to full-time employees or face potential penalties.

How Does the ACA Define Full-Time and FTE Employees?

• Full-time employee: Works at least 30 hours per week or 130 hours per month.

• Part-time employee: Their hours are combined to determine the number of FTEs.

How to Calculate FTEs for ACA Compliance

To calculate FTEs for ACA compliance, follow these steps:

Step 1. Define Full-Time Hours: The ACA defines full-time employees as those working at least 30 hours per week or 130 hours per month.

Step 2. Identify Employee Hours Worked: Collect the total number of hours worked by all employees, including full-time, part-time, and seasonal employees.

Step 3. Apply the ACA FTE formula: FTE is calculated as FTE= Total Hours worked by part time employes divided by 30; plus total number of full time employees.

FTE Calculation Template

Final Thoughts

Calculating FTEs is crucial for determining ALE status under the ACA. If your company has 50 or more FTEs, you must comply with ACA employer mandate rules to provide health insurance coverage. Keeping accurate FTE records ensures compliance and helps avoid penalties.

Would you like help setting up an FTE calculator for ACA compliance? Contact your Rose Street Advisors Team today! If you are not a current client of Rose Street Advisors, please feel free to contact us at 269-552-3200 or contact@rosestreetadvisors.com to speak to someone.

Justine Dickens

EMPLOYEE BENEFITS ADVISOR

Justine is a devoted and meticulous team member with a passion to educate and support business partners and their employees. Since 2013, Justine’s commitment to her clients has allowed her to instill confidence and stability in the benefits packages offered to their employees. Her strengths allow her to communicate efficiently, focus on customization and understand the complexities of an ever changing industry. She is a Dale Carnegie Graduate and has her NAHU Self-Funded Certification.

When she is not working, Justine is busy running her son and daughter to their practices and games and volunteering in the community. She enjoys playing golf, hiking and spending time with her family and friends.

Understanding the Affordable Care Act: What Employers Need to Know when Moving Above or Below 50 FTEs

The Affordable Care Act (ACA) has specific regulations that impact employers based on the size of their workforce. One of the most critical thresholds is 50 full-time equivalent (FTE) employees. Crossing this line, whether moving above or below, triggers changes in employer obligations, particularly concerning health coverage requirements, reporting duties, and compliance with additional labor laws such as the Family and Medical Leave Act (FMLA). Employers need to be proactive in understanding these obligations to avoid penalties and ensure compliance.

Understanding the 50 FTE Threshold

The ACA distinguishes between small and large employers based on whether they have 50 or more FTEs. Here's what employers should consider:

Employers with Fewer Than 50 FTEs

To qualify for an HSA, you must:

• Not Subject to the Employer Mandate: Businesses with fewer than 50 FTEs are not required to provide health insurance to their employees.

• Mental Level Tiers: Coverage is offered in canned plans rated from Platinum to Bronze.

• Pediatric Dental & Pediatric Vision: These employers are subject to specific plan details for Pediatric members and their dental and vision services.

• Exemption from ACA Reporting Requirements: Unlike larger employers, small businesses do not need to comply with the ACA’s employer mandate reporting requirements.

Employers with 50 or More FTEs

• Subject to the Employer Mandate: Large employers must offer health insurance to at least 95% of their full-time employees (and their dependents) that meets minimum value and affordability standards.

• Reporting Requirements: Employers must file Forms 1094-C and 1095-C with the IRS to report coverage information. Generally, Forms 1094-C and 1095-C must be filed by February 28^th if filing on paper (or March 31^st if filing electronically).

• Potential Penalties: Failure to offer coverage or providing coverage that does not meet affordability standards can result in significant penalties under the Employer Shared Responsibility Provisions (ESRP).

Impact on the Family and Medical Leave Act (FMLA)

• Applicability: The FMLA applies to employers with 50 or more employees within a 75-mile radius.

• Employee Eligibility: Employees must have worked at least 1,250 hours over the past 12 months.

• Requirement: Employers must provide up to 12 weeks of unpaid, job-protected leave for qualified medical and family reasons.

Steps for Employers Moving Above or Below 50 FTEs

1. Monitor Workforce Size: Use the ACA’s FTE calculation to determine whether your business is approaching the 50-employee threshold. This includes assessing Common Ownership rules.

2. Plan for Compliance: If expanding above 50 FTEs, prepare for employer mandate requirements, reporting obligations, and possible FMLA coverage.

3. Assess Health Plan Offerings: Ensure any provided insurance includes the 10 essential health benefits and meets affordability standards.

4. Stay Updated on ACA Changes: Regulations evolve, and staying informed helps avoid penalties and ensure legal compliance.

5. Consult Experts: Work with HR professionals, legal advisors, and benefits consultants to navigate ACA compliance effectively.

Conclusion

Crossing the 50 FTE threshold under the ACA is a critical transition for employers. Whether moving above or below this benchmark, businesses must understand their obligations related to health insurance, reporting requirements, and employee benefits. Staying proactive in compliance efforts can help employers avoid costly penalties while providing quality benefits to their workforce. For businesses approaching this threshold, now is the time to review policies, consult experts, and develop a strategic plan to ensure a smooth transition under ACA regulations. Contact your Rose Street Advisors team if you have additional questions. If you are not a current client of Rose Street Advisors, please feel free to contact us at 269-552-3200 or contact@rosestreetadvisors.com to speak to someone.

Justine Dickens

EMPLOYEE BENEFITS ADVISOR

What is a Collective Investment Trust (CIT)? And How it Differs from a Mutual Fund

As a retirement plan sponsor or committee member, you're probably familiar with mutual funds as the go-to investment option in most 401(k) and 403(b) plans. But you may have also come across Collective Investment Trusts, or CITs, and wondered: How are theses different? Are they better? Should we consider them for our plan?

Let's take a closer look at CITs, how they compare to mutual funds, and what you need to know when evaluating them for your retirement plan lineup.

What is a Collective Investment Trust (CIT)?

A Collective Investment Trust (CIT) is a pooled investment vehicle, similar to a mutual fund, that's sponsored by a bank or trust company. but unlike mutual funds, CITs are only available to qualified retirement plans (like 401(k)s, 403(b)s, and certain 457 plans) and not sold to the general public.

Because of this, CITs are regulated by banking authorities, such as the Office of the Comptroller of the Currency (OCC), rather than the SEC.

CITs vs. Mutual Funds: What's the Difference?

Here's a quick side-by-side comparison to help clarify the key differences:

Feature	Mutual Funds	CITs
Who Can Invest?	Anyone (individuals or institutions)	Only qualified retirement plans
Regulated By	SEC	OCC or state banking regulators
Disclosure	Prospectus and public figures	Trust documents and fact sheets (not public)
Ticker Symbol?	Yes – Searchable	Usually no
Pricing	Daily Net Asset Value (NAV)	Also uses daily NAV
Fees	May include SEC and marketing expenses	Typically lower- no 12b-1 or distribution costs
Customization	Limited	Often customized by plan size or ivestment strategy

Why are more plans using CITs?

One word: Cost.

Because CITs aren't required to register with the SEC or engage in public marketing, they often carry lower expense ratios than comparable mutual funds. In fact, it's common for CITs to be managed by the same portfolio managers using the same strategies as a mutual fund, just with reduced overhead.

Real-World Example:

A small-sized 401(k) plan with $5 million in assets was using a target-date mutual fund with an average expense ratio of 0.45%. By switching to the CIT version of the same strategy, they secured a 0.30% expense ratio, savings 15 basis points annually. Over time, those savings can significantly boost participant account balances.

How Do CITs Work Operationally?

While the structure behind the scenes is different, the participation experience is nearly identical to a mutual fund:

• Daily Pricing: CITs are priced once a day, just like mutual funds.

• Statements: CITs appear on participant statements and online portals with clear naming and balances.

• Trading: Transactions (buy/sell) typically follow the same trade cycle as mutual funds.

To most plan participants, CITs look and feel just like mutual funds.

Things to Keep in Mind

CITs have plenty of upside—but also a few nuances you’ll want to consider:

• Transparency: No public prospectus or ticker symbol means you’ll need to rely on provider fact sheets and trust documents for info.

• Education: Because they’re less familiar, you may need to explain to participants what a CIT is and why it’s in the plan.

• Access: Not all recordkeepers or custodians support CITs, and some CITs may have investment minimums.

• Documentation: Be sure to review and retain the participation agreement and declaration of trust for any CITs you offer.

Your Fiduciary Role

As a fiduciary, your responsibility is to select, monitor, and document plan investments in the best interest of participants. While CITs can be a great low-cost option, they still require the same level of due diligence:

• Review performance and fees regularly

• Understand the underlying strategy and manager

• Benchmark against peers

• Maintain written records of your evaluations

Bottom Line

CITs are becoming more common in retirement plan lineups for a reason—they offer cost savings, flexibility, and institutional-quality strategies. If your plan has the size and structure to support them, it’s worth exploring CITs as part of your investment menu.

Want help evaluating whether CITs make sense for your plan? Let’s talk—we can walk through the pros, cons, and how to make an informed decision that supports your fiduciary duties.

Scott Higgins | AIF ®, CFP®, CPFA®, NSSA®

Financial Advisor

Since 2012 at Rose Street, Scott has been responsible for helping the firm’s individual wealth management clients with income strategies for retirement and consulting with employers with their employee retirement plans. In free time, he enjoys golf, biking, skiing, cooking, and traveling. Fun Fact, Scott has a hobby of filling growlers with coins!

Securities and Investment Advisory Services Offered Through M Holdings Securities, Inc., a Registered Broker/Dealer and Investment Adviser, Member FINRA/SIPC. Rose Street Advisors is independently owned and operated. #4520110

Tracking Variable Hour Employees: Understanding Measurement and Administrative Periods

Employers with variable hour employees face unique challenges when it comes to tracking hours and determining health insurance eligibility. Under the Affordable Care Act (ACA), businesses must use specific methods to measure employee hours and ensure compliance with health coverage requirements. Understanding the look-back measurement period, administrative periods, and stability period is crucial for staying compliant and avoiding penalties.

Please note, only employers with 50 or more full-time equivalent (FTE) employees are required to offer health insurance.

The Look-Back Measurement Period

The look-back measurement period is used to determine whether a variable hour employee qualifies as a full-time employee (30 or more hours per week) under the ACA. Employers can select a measurement period between 3 and 12 months to track an employee's hours worked. If the employee averages at least 30 hours per week over this period, they are considered full-time and must be offered health insurance coverage.

The Administrative Period

The administrative period allows employers time to review hours, determine eligibility, and complete the necessary steps to offer coverage. This period cannot exceed 90 days and typically follows the look-back measurement period. it is important to note that the administrative period should not create a gap in coverage if an employee is determined to be eligible.

The Stability Period

Once an employee is deemed full-time, they must be offered health insurance for a stability period, which must be at least as long as the measurement period but no shorter than six months. Even if the employee's hours drop below full-time during the stability period, they remain eligible for coverage until the end of this period.

Who is Eligible for Health Insurance?

An employee is eligible for employer-sponsored health insurance if they work an average of 30 or more hours per week during the look-back measurement period. Full-time employees (those with a consistent schedule of 30+ hours per week) are generally eligible immediately, while variable hour employees must first complete a measurement period.

How Long Are Employees Eligible?

Once an employee qualifies for health insurance, they remain eligible throughout the stability period, regardless of any fluctuations in their work hours. If they continue to meet full-time criteria in subsequent measurement periods, their eligibility continues. If their average hours fall below 30 during a measurement period, they may lose eligibility once the stability period ends.

Key Takeaways for Employers

1. Chose a Measurement Period: Employers must select a look-back measurement period (3-12 months) to assess variable hour employees' eligibility

2. Account for Administrative Processing: The administrative period allows time to determine eligibility and offer coverage but cannot delay or shorten an eligible employee's access to benefits.

3. Maintain Stability Period Compliance: Employees determined to be full-time must receive coverage for the entre stability period, even if their hours decrease.

4. Avoid Penalties: Failure to properly track and offer coverage to eligible employees can result in significant ACA penalties.

Properly tracking variable hour employees and adhering to ACA guidelines ensures compliance and provides employees with the benefits they are required to be offered. Employers should review their policies regularly and leverage technology to streamline the tracking process. Have additional questions? Contact your Rose Street Advisors team today! If you are not a current client of Rose Street Advisors, please feel free to contact us at 260-552-3200 or contact@rosestreetadvisors.com to speak to someone.

Justine Dickens

EMPLOYEE BENEFITS ADVISOR

Simple IRA vs 401(k): Should You Consider Upgrading?

As your company evolves, your retirement plan should keep pace. If you're considering upgrading from a SIMPLE IRA to a 401(k), here are the top five advantages and considerations to keep in mind.

Top 5 Advantages of a 401(k)

1. Higher Contribution Limits

Employees can defer up to $23,500 in 2025 (plus $7,500 catch-up if age 50+), compared to $16,500 for SIMPLE IRAs. That means more savings potential for owners and staff.

2. Greater Plan Flexibility

401(k) plan is a more competitive and familiar benefit, especially for high earners or experiences professionals.

3. Enhanced Talent Attraction & Retention

A 401(k) plan is a more competitive and familiar benefit, especially for high earners or experienced professionals.

4. Expanded Employer Contribution Options

Unlike SIMPLE IRAs with fixed formulas, 401(k) plans let you tailor your matching or profit-sharing strategy based on your budget and goals.

5. Long-Term Scalability

401(k)s can grow with your business and integrate advanced strategies like Safe Harbor provisions or Cash Balance plans as your company matures.

Top 5 Considerations or Trade-Offs

1. Increased Administrative Complexity

401(k)s requires IRS filings (e.g., Form 5500), nondiscrimination testing's, and possibly annual audits once your plan grows.

2. Higher Setup and Maintenance Costs

Compared to SIMPLE IRAs, 401(k)s typically involve provider, TPA, and advisory fees, but startup tax credits may offset these costs for small employers.

3. Fiduciary Responsibility

Sponsors of 401(k) plans are fiduciaries, meaning you're responsible for plan oversight, investment selection, and cost monitoring.

4. More Time and Decision-Making Required

You'll need to work with a recordkeeper, advisor, and/or TPA to select features, manage compliance, and communicate with participants.

5. Transition Planning is Key

While SECURE Act 2.0 now allows mid-year transitions to Safe Harbor 401(k)s, timing and communication with employees are still critical.

Ready to Evaluate Your Options?

Let's talk about whether a 401(k) plan makes sense for your team, and how to make the transition smoothly and strategically.

Scott Higgins | AIF ®, CFP®, CPFA®, NSSA®

Financial Advisor

Health Savings Account (HSA) FAQs: Everything You Need to Know

A Health Savings Account (HSA) is a powerful tool that helps individuals save for medical expenses while enjoying tax advantages. If you're considering opening an HSA or want to maximize its benefits, here are some of the most frequently asked questions to guide you.

1. What is an HSA?

An HSA is a tax-advantaged savings account designed for individuals with a high-deductible health plan (HDHP). The funds in the account can be used for qualified medical expenses, and contributions, earnings and withdrawals for medical purposed are tax-free.

2. Who is eligible to open an HSA?

To qualify for an HSA, you must:

• Be enrolled in an HDHP

• Not be covered by any other non-HDHP insurance (except certain exceptions like dental and vision plans)

• Not be enrolled in Medicare

• Not be claimed as a dependent on someone else's tax return

3. What are the contribution limits for an HSA?

• Individuals: $4,300

• Families: $8,550

• Catch-up contribution (for those 55 and older): An additional $1,000

4. What expenses are covered under an HSA?

• Doctor visits and hospital stays

• Prescription medications

• Dental and vision care

• Medical equipment

• Mental health services

5. What happens if I use HSA funds for non-medical expenses?

If you withdraw HSA funds for non-qualified expenses before age 65, you'll incur a 20% penalty plus income tax. After age 65, non-medical withdrawals are subject to income tax but no penalty.

6. Can HSA funds be invested?

Yes, many HSA providers allow you to invest your funds in stocks, bonds, or mutual funds to grow your savings tax-free.

7. What happens to my HSA if I switch jobs or retire?

HSAs are portable, meaning they stay with you even if you change jobs or retire. Once you turn 65, you can use HSA funds for any purpose without penalties, through non-medical expenses will be taxed as regular income.

8. Can I have both an HSA and an FSA?

Typically, you cannot contribute to both a Health Savings Account (HSA) and a Flexible Spending Account (FSA) simultaneously, except for a limited-purpose FSA (used for dental and vision expenses only). Of course, because Dependent Care FSAs aren't connected to medical expenses, they are not impacted by HSA contributions.

9. Do HSA funds expire?

No, HSA funds roll over year to year. Unlike FSAs, there is no "use it or lose it" rule, so your savings can grow over time.

10. How do I open an HSA?

You can open an HSA through a bank, credit union, insurance company, or other financial institutions. Many employers also offer HSAs as part of their benefits packages.

Final Thoughts

An HSA can be an excellent way to save for medical expenses while benefiting from tax advantages. Understanding the eligibility requirements, contribution limits, and investment options can help you make the most of your HSA.

Still have questions? Contact your Rose Street Advisors team to see if an HSA is right for you! If you are not a current client of Rose Street Advisors, please feel free to contact us at 269-552-3200 or contact@rosestreetadvisors.com to speak to someone

Justine Dickens

EMPLOYEE BENEFITS ADVISOR

Trustee vs. Authorized Signer: Who Does What in Your Retirement Plan?

When managing a retirement plan, such as a 401(k), it's important to understand the distinct roles involved in overseeing and operating the plan. Two key roles that often get confused are the plan trustee and the authorized signer. While both are essential to the plan's operation, their responsibilities and authority differ significantly.

What is a Plan Trustee?

The plan trustee is a fiduciary who holds legal responsibility for the plan's assets. This role required the trustee to act in the best interest of plan participants and their beneficiaries. Trustees are responsible for making decisions about investments, ensuring the plan complies with regulatory requirements, and safeguarding the plan's assets.

Key Responsibilities of a Plan Trustee:

1. Oversight of Plan Investment: Trustees ensure that investments are appropriate, diversified, and align with the plan's goals.

2. Fiduciary Duty: Trustees must act solely in the interests of participants, avoiding any conflicts of interests.

3. Compliance: Trustees ensure the plan complies with the Employee Retirement Income Security Act (ERISA) and other laws.

4. Asset Custody: Trustees oversee the safekeeping of the plan's funds.

What is an Authorized Signer?

An authorized signer is someone designated to sign documents, such as plan-related agreements, distribution requests, or administrative forms. While an authorized signer plays an operation role, they do not hold the fiduciary responsibility of a trustee.

Key Responsibilities of an Authorized Signer:

1. Administrative Actions: Authorized signers execute day-to-day tasks like signing checks, approving distributions, or authorizing vendor payments.

2. Limited Scope or Authority: Their authority is confined to the actions specified by the plan sponsor, and they don't have decision-making power over plan investments.

3. Non-Fiduciary Role: Unlike a trustee, an authorized signer is not responsible for the overall management or compliance of the plan.

Main Differences Between a Trustee and an Authorized Signer

Aspect	Plan Trustee	Authorized Signer
Fiduciary Responsibility	Yes, must act in the best interest of participants.	No, acts as directed by the plan sponsor.
Decision-Making Power	Has authority over investments and plan management.	Limited to executing specific administrative tasks.
Legal Liability	Bears legal liability for fiduciary decisions.	No legal liability for plan compliance or investments.
Scope of Role	Broad, encompassing overall plan oversight.	Narrow, focused on administrative duties.

Why Does This Matter?

Understanding these roles is crucial for ensuring your retirement plan is managed effectively and compliant with applicable laws. Appointing the right individuals to these roles, and understanding the scope of their responsibilities, can help protect the plan sponsor and ensure participants receive the benefits they deserve.

Final Thoughts

While a trustee oversees the plan with fiduciary responsibility, an authorized signer handles administrative tasks without the same level of legal obligation. Clearly defining these roles can improve the efficiency and compliance of your plan operations.

Scott Higgins | AIF ®, CFP®, CPFA®, NSSA®

Financial Advisor

What is RxDC Reporting?

RxDC (Prescription Drug Data Collection) reporting is a requirement under the Consolidated Appropriations Act (CAA) of 2021. The purpose of this reporting is to provide the Centers for Medicare & Medicaid Services (CMS) with data on prescription drug costs and health care spending. The information collected helps federal agencies analyze trends in drug pricing, understand how prescription costs impact premiums, and promote transparency in the healthcare market.

Employers sponsoring health plans—whether fully insured, level-funded, or self-funded—must ensure compliance with RxDC reporting requirements. Understanding your responsibilities based on the type of plan you offer is crucial for compliance and avoiding potential penalties.

Employer Responsibilities by Plan Type

Fully Insured Health Plans

Employers with fully insured health plans generally have limited responsibilities regarding RxDC reporting. The health insurance carrier is responsible for submitting the required data to CMS. However, employers should:

•Confirm with their insurer that the reporting will be completed on their behalf.

•Request documentation from the insurer confirming submission.

•Retain records of compliance in case of future audits or inquiries.

Level-Funded Health Plans

Level-funded plans are a hybrid between fully insured and self-funded plans, where the employer pays a set monthly amount but retains some financial risk. The reporting responsibilities for level-funded plans can vary depending on the insurer’s role. Employers should:

•Determine whether their carrier will handle the RxDC reporting.

•If the insurer does not report on their behalf, coordinate with third-party administrators (TPAs) or pharmacy benefit managers (PBMs) to ensure data submission.

•Maintain documentation of the reporting process and ensure compliance deadlines are met.

Self-Funded Health Plans

For self-funded plans, the employer holds the primary responsibility for RxDC reporting. However, third-party administrators (TPAs) or pharmacy benefit managers (PBMs) may assist with the process. Employers should:

•Confirm if their TPA or PBM will submit the RxDC report.

•If the TPA or PBM does not handle submission, ensure data collection and timely reporting to CMS.

•Keep records of the submission process for compliance verification.

Key Deadlines and Compliance Considerations

RxDC reporting is due annually, typically by June 1st for data from the previous calendar year. Employers should:

•Start discussions with insurers, TPAs, or PBMs well in advance of the deadline.

•Ensure all required data—including total health care spending, prescription drug costs, and premium information—is accurately compiled.

•Monitor regulatory updates, as reporting requirements may evolve over time.

Final Thoughts

RxDC reporting is an essential compliance requirement for employer-sponsored health plans. While fully insured employers have minimal direct responsibilities, those with level-funded and self-funded plans must take a proactive approach to ensure timely and accurate reporting. By working closely with insurers, TPAs, and PBMs, employers can fulfill their obligations, avoid compliance risks, and contribute to greater transparency in healthcare costs.

If you have questions about your responsibilities or need assistance with RxDC reporting, consult your Rose Street Advisors team for assistance. If you are not a current client of Rose Street Advisors, please feel free to contact us at 269-552-3200 or contact@rosestreetadvisors.com to speak to someone.

Justine Dickens

EMPLOYEE BENEFITS ADVISOR

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