Group health plan sponsors that provide prescription drug coverage to anyone eligible for Medicare Part D coverage—such as employees age 65 or older—must annually disclose to the federal Centers for Medicare & Medicaid Services (CMS) whether that coverage is actuarially equivalent to Medicare Part D prescription drug coverage (i.e., whether it's "creditable" or "non-creditable").
The disclosure obligation applies to all plan sponsors that provide prescription drug coverage, even those that don't offer prescription drug coverage to retirees. Because the disclosures are due 60 days after the start of the plan year, calendar-year plans must submit this year's disclosure to the CMS by March 1.
Entities that are required to provide a disclosure of creditable coverage status to CMS must complete the online Disclosure to CMS Form.
Disclosure to CMS Guidance and Instructions
Disclosure to CMS Online Form
CMS Resources
Articles
Medicare Part D Creditable Coverage Online Disclosure Due March 1
Morgan Lewis | Feb 2025
Medicare Part D Disclosures due by March 1st for Health Plans
Parrot Benefit Group | Feb 2025
March 1 Deadlines for Group Health Plans
Venable | Jan 2025
Compliance Reminder: CMS Medicare Part D Reporting Due Beginning of March 2025
Risk Strategies | Jan 2025
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