"[CMS] recently posted a number of FAQs that should ease the prescription drug data collection (RxDC) reporting burden for employers sponsoring complex group health plans.... Regulators confirmed that they will accept multiple data files of the same type from the same group health plan ... if there are 'extenuating circumstances' preventing vendors from working together. CMS wants to use the plan-specific files to connect a particular group health plan with the multiple data files submitted by its vendors, and provides sample P2 files for a variety of situations."