Employers sponsoring group health plans that provide prescription drug coverage to individuals eligible for Medicare Part D coverage must annually disclose to the Centers for Medicare and Medicaid Services (CMS) whether that coverage is considered creditable or non-creditable. To be considered creditable, the plan’s drug coverage must be at least actuarially equivalent to Medicare Part D prescription drug coverage.
This reporting requirement applies to both self-funded and fully insured group health plans and also applies whether the prescription drug coverage is primary or secondary to Medicare.
This annual disclosure must be provided to CMS within 60 days of the start of the plan year.
For employers with calendar year plans (January 1 – December 31, 2023), the deadline to complete this disclosure reporting to CMS is Thursday, February 29, 2024 (typically March 1 each year; since 2024 is a leap year, the deadline is February 29, 2024).
Employers must also complete disclosure reporting to CMS within 30 days following either:
- A change in the creditable coverage status of the prescription drug coverage or
- The termination of the plan’s prescription drug coverage.
Online Disclosure to CMS
To complete this CMS disclosure online, click here. For additional CMS guidance and instructions on this reporting requirement, click here. CMS’s Creditable Coverage webpage can be accessed here.
CMS Disclosure Form Required Data Fields Include:
- Details on the entity offering coverage, such as the employer sponsoring the benefit plan, employer address and phone number, and the employer EIN
- Type of coverage
- Number of prescription drug options offered
- Creditable coverage status
- Period covered by the disclosure notice (plan year)
- 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, if applicable.
Medicare Part D Creditable
Coverage Notice
Please note that this annual disclosure reporting to CMS is different from the requirement to provide Part D-eligible individuals with a notice disclosing the creditable status of the plan’s prescription drug coverage before October 15 of each year.
Determine whether a group health plan’s prescription drug coverage is considered creditable or non-creditable here.
Employer Action
Employers with calendar year plans (Jan 1 to Dec 31, 2023) are advised to take action now and complete the online disclosure reporting to CMS by the deadline of Thursday, February 29, 2024.
Reach out to your eBen account team with any questions or contact us directly to learn more!
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