26 February 2018 In Blog style

For prescription drug plans that renewed on January 1, 2018, the deadline for the on-line filing to the Centers for Medicare & Medicaid Services (CMS) is February 28, 2018.  This deadline is within 60 days after the beginning date of the plan year.
Group health plan sponsors are required to disclose to CMS whether their prescription drug coverage is creditable or non-creditable.  In general, a group health plan’s prescription drug coverage is considered creditable if its actuarial value equals or exceeds the actuarial value of the Medicare Part D prescription drug coverage.

The disclosure must be made to CMS on an annual basis, and upon any change that affects whether the coverage is creditable. More specifically, the Medicare Part D disclosure notice must be provided within the following timeframes:

  *   Within 60 days after the beginning date of the plan year for which the entity is providing the disclosure to CMS;
  *   Within 30 days after the termination of a plan’s prescription drug coverage; and
  *   Within 30 days after any change in the plan’s creditable coverage status.

Plan sponsors are required to use the online disclosure form at
https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html

Please refer to the attached Legislative Brief for additional details and let me know if you have any questions.

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