Medicare Part D: Disclosure Notice to CMS

17 July 2017 By Barry E. Fields

Employers with health plans that provide prescription drug coverage to individuals who are eligible for Medicare Part D are subject to certain disclosure requirements. One of these requirements provides that plan sponsors must disclose to the Centers for Medicare and Medicaid Services (CMS) on an annual basis and at other select times, whether the plan's prescription drug coverage is creditable or non-creditable.

This disclosure is required regardless of whether the health plan’s coverage is primary or secondary to Medicare. Plan sponsors are required to use the online form on the CMS Creditable Coverage Web page to make this disclosure.

The plan sponsor must complete the online disclosure within 60 days after the beginning of the plan year. For calendar year health plans, the deadline for the annual online disclosure is March 1 (Feb. 29 for leap years).

Employers that are required to report to CMS should work with their advisors to determine whether their prescription drug coverage is creditable or non-creditable.

A group health plan’s prescription drug coverage is considered creditable if it is at least as generous as Medicare Part D prescription drug coverage.

There are two permissible methods to determine whether coverage is creditable—a simplified determination method and an actuarial determination method.

CMS has also provided instructions for detailed descriptions of these data fields and guidance on how to complete the form.

Please let me know if you have any questions.


Barry E. Fields
Vice President, Employee Benefits
JGS Insurance
960 Holmdel Road, Bldg. 1
Holmdel, NJ 07733
Phone:  732-837-1068
Cell:  908-406-7000
Fax:  732-834-0233

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Last modified on Monday, 17 July 2017 17:52

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