Group health plan sponsors are required to complete an online disclosure form with CMS on an annual basis, indicating whether the plan's prescription drug coverage is creditable or non-creditable. This disclosure requirement applies when an employer-sponsored group health plan provides prescription drug coverage to individuals who are eligible for coverage under Medicare Part D.

For calendar year health plans, the deadline for the annual online disclosure is March 1. To determine if the CMS reporting requirement applies, employers should verify whether their group health plans cover any Medicare-eligible individuals at the start of each plan year.

Plan sponsors are required to use the online disclosure form on the CMS website. The disclosure form lists the required data fields that must be completed in order to generate the disclosure notice to CMS, such as types of coverage, number of options offered, creditable coverage status, period covered by the disclosure notice, number of Part D-eligible individuals covered, date the creditable coverage disclosure notice is provided to Part D-eligible individuals, and change in creditable coverage status. 

In addition to the annual disclosure to CMS, group health plan sponsors must disclose to individuals who are eligible for Medicare Part D whether the plan’s prescription drug coverage is creditable. At a minimum, creditable coverage disclosure notices must be provided to individuals at the following times:

  1. Prior to the Medicare Part D annual coordinated election period—beginning Oct. 15 through Dec. 7 of each year
  2. Prior to an individual’s initial enrollment period for Part D
  3. Prior to the effective date of coverage for any Medicare-eligible individual who joins the plan
  4. Whenever prescription drug coverage ends or changes so that it is no longer creditable or becomes creditable
  5. Upon a beneficiary’s request

Please note:
The above only applies to Calendar Year Plans. Plan Year Groups have 60 days after the beginning date of their plan year to submit their disclosure. This disclosure is requested by Center for Medicare and Medicaid Services (CMS) for informational purposes only and there is no penalty attached to the requirement. 

As always, the Towne Benefits team is here to help should you have any questions regarding the Medicare Part D disclosures. 

Filed Under: Benefits Briefs