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[Deadline] Medicare Part D Disclosures

Medicare Part D

If your employer-sponsored group health plan provides prescription drug coverage to individuals who are eligible for coverage under Medicare Part D, you are subject to Medicare Part D disclosure requirements.


Disclosure Requirements

Employers with calendar year plans must complete a Medicare Part D online disclosure form with the Centers of Medicare & Medicaid Services (CMS) by March 1, 2019. Disclosure is required regardless of whether the health plan’s coverage is primary or secondary to Medicare.

The disclosure states whether your prescription plan coverage is creditable or non-creditable. Employers can check with their health insurance carrier to see if a determination has been made or if they need to make one themselves. Depending on the plan design, either a simplified method or an actuarial determination can be made. CMS’ website also provides additional guidance and instructions on making a determination.


Disclosure Timing

The online disclosure form must be completed annually and in the following situations:

  • 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.


Individual Disclosures

Employers must also disclose to eligible Medicare individuals if the plan’s prescription drug coverage is creditable. Creditable coverage disclosure notices must be provided to individuals:

  • Prior to Medicare Part D annual election period (October 15-December 7)
  • 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 that makes it no longer creditable or non-creditable
  • Upon a beneficiary’s request

In addition to providing the notice to individuals before October 15 of each year, employers should consider including a notice in their plan enrollment materials for new hires. Model disclosure notices are available on CMS’ website.

For more information, please download the bulletin.


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Jason Rushton

Jason Rushton

Jason Rushton’s personal philosophy is to improve himself daily - as a father, basketball coach, and benefits consultant. He is one of those rare, down-to-earth people who is honest, hard-working, and loyal. Jason’s customers aren’t just clients to him but rather long-term partners. Jason has been providing full benefits consulting in Michigan since 2009. He has worked with several local Michigan unions on their collective bargaining process including mediation, negotiations, writing contract language, and more. He has completed the MSBO Leadership Institute program, been a featured speaker at the MSBO and MASA conferences and has been on several panel discussions about the Affordable Care Act. Jason is a licensed life and health insurance agent. He provides full benefit consulting for schools, cities, and counties in Michigan, Ohio, and North Carolina.