Employers sponsoring group health plans that provide prescription drug coverage to individuals eligible for Medicare Part D coverage1 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 is required 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 Wednesday, March 1, 2023.
Employers must also notify CMS within 30 days following either a change in the creditable coverage status of the prescription drug coverage or the termination of the coverage.
To complete this CMS disclosure online, click here. For additional CMS guidance and instructions on this reporting requirement, click here.
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.
Reach out to your Risk Strategies representative with any questions or contact us directly at benefits@risk-strategies.com.
1 Includes Medicare-eligible employees, retirees, spouses, or dependents.