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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.
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.
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.
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.