Compliance Alerts

Medicare Part D disclosure to CMS

Deadline:

January 03, 2019

Applicability:

Group health plans that provide prescription drug coverage to individuals who are eligible for Medicare Part D

Description

Group health plan sponsors that provide prescription drug coverage to Medicare Part D-eligible individuals must disclose to the Centers for Medicare & Medicaid Services (CMS) whether prescription drug coverage is creditable or non-creditable. In general, a plan’s prescription drug coverage is creditable if its actuarial value equals or exceeds the actuarial value of the Medicare Part D prescription drug coverage.

Plan sponsors must make the disclosure annually and at other select times, using CMS’ online disclosure form. Plan sponsors must submit the annual disclosure to CMS within 60 days after the beginning of the plan year. For the calendar year plans, the deadline is March 1, 2019.