As part of the Medicare Part D program, group health plan sponsors are required to complete an online disclosure form with the Centers for Medicare & Medicaid Services (CMS) indicating whether the plan’s prescription drug coverage is creditable or non-creditable.
Plan sponsors 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, 2015.
To help your company understand and meet its compliance requirements, below is a brief overview.
Submitting Your Disclosure Online
Plan sponsors are required to use the online disclosure form on the CMS Creditable Coverage webpage.
CMS has also provided instructions for detailed descriptions of the required data fields and guidance on how to complete the form.
The required data fields include items 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
- Change in creditable coverage status
Separate Requirement to Notify Individuals
Please note that in addition to the annual disclosure to CMS, group health plan sponsors are required to disclose to individuals who are eligible for Medicare Part D whether the plan’s prescription drug coverage is creditable. This notice must be made at the following times:
- Prior to the Medicare Part D annual coordinated election period — beginning Oct. 15 through Dec. 7 of each year
- Prior to an individual’s initial enrollment period for Part D
- Prior to the effective date of coverage for any Medicare-eligible individual who joins the plan
- Whenever prescription drug coverage ends or changes so that it is no longer creditable or becomes creditable
- Upon a beneficiary’s request.
I hope that you find this brief overview helpful as you seek to meet your compliance requirements.
For a more in-depth look at the additional rules supporting this disclosure requirement, please download our Compliance Bulletin in the CBGconnect portal.