Each year, applicable employers are required to complete an online disclosure with CMS and report whether their health plan’s prescription drug coverage is Medicare Part D creditable or non-creditable.
Plan sponsors are required to report 60 days after the start of the plan year. Thus, if you renewed January 1, 2017, this year’s deadline is March 1, 2017.
Online Disclosure Method
- How to File: Plan sponsors are required to use the online disclosure form on the CMS Creditable Coverage Web page.
- What to Disclose: 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.
- Additional Instructions: CMS has also provided instructions for detailed descriptions of these data fields and guidance on how to complete the form.
Separate Employee Disclosure Requirement
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. The deadline for distributing those notices is October 14th.
I hope that you find this compliance update helpful. For a more detailed look at this requirement, I encourage all clients to download our Compliance Bulletin within the CBGconnect portal. If you have any questions, please contact myself or another member of the CBG Benefits team.