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Medicare Part D Disclosures Due in February

notebook on desk that says Medicare Part d

1.5 minute read

Group health plan sponsors must annually complete an online form with the Centers for Medicare & Medicaid Services (CMS) to disclose if their prescription drug coverage is creditable or non-creditable. This requirement applies to employer-sponsored plans covering individuals eligible for Medicare Part D.


CMS Disclosure Deadline

Online disclosure must be completed within 60 days after the beginning of the plan year. For calendar year health plans, the annual online disclosure deadline is Feb. 29, 2024 (since 2024 is a leap year). In addition to the annual disclosure requirement, disclosure to CMS must be made within 30 days of any change in coverage creditability or termination of prescription drug coverage.


Online Disclosure Method

Plan sponsors must use the online disclosure form on the CMS website to comply with the requirement. The form includes data fields for types of coverage, options offered, creditable coverage status, disclosure period, number of Part D-eligible individuals covered, date of disclosure notice, and changes in creditable coverage status. The CMS has also provided guidance and instructions on completing the form.


Action Steps

Employers should check if their group health plans cover Medicare-eligible individuals (including active employees, disabled employees, COBRA participants, retirees, and their covered spouses and dependents) at the start of each plan year to determine if CMS reporting is required. They should also consult with advisors to assess the creditability of their prescription drug coverage. Employers can visit CMS' creditable coverage website for the online disclosure form and instructions. Download the bulletin for more details.

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National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.

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Steve Smith

Steve Smith

Steve Smith, Employee Benefits Consultant for National Insurance Services, has his energy level permanently set at “high.” His maxim is “work hard, play hard.” Steve’s an expert in getting groups of people working together for a higher cause. Minnesota schools, cities, and counties rely on Steve’s unique and creative ideas of engaging employees in their own health and wellness to lower utilization trends. He has 20+ years in the health insurance field doing compliance, cost mitigation, utilization, analytics, wellness plans, and strategic planning. Steve is a licensed insurance agent and holds the designations for Managed Healthcare Professional (The Health Insurance Association of America), Certified Patient Protection and Affordable Care Act Professional (National Association of Health Underwriters), and Group Benefits Disability Specialist (Hartford School of Insurance). He specializes in Employee Benefits Consulting for Minnesota schools, cities, and counties including fully insured, self-insured, and stop-loss plans.