All group health plans that provide prescription drug coverage to Medicare Part D eligible individuals (whether actively working, retired, or disabled) are required to notify CMS whether or not the coverage that is provided is creditable. This disclosure is required whether the coverage is primary or secondary to Medicare.
Employers must file their Disclosure Notice through the CMS website at: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html
Instructions and guidance on completing the notice are available at: http://www.cms.hhs.gov/CreditableCoverage
NOTE: If you are offering an actual Part D Plan, you are exempt from this filing requirement. Employers who have applied for a retiree drug subsidy are NOT required to complete this form.
You will need the following information to complete the Disclosure Notice:
- Employer’s name, address and phone number
- Employer’s Federal Tax Identification Number (EIN)
- Type of coverage (most will be Group Health Plan: Employer Sponsored Plan or Local Government)
- Number of prescription drug plans offered by the employer
- Whether or not the prescription drug plans are creditable
- The plan year beginning and end dates, the estimated number of Part D eligible individuals expected to be covered under the plans, the estimated number of plan participants excepted to be covered through an employer/union group health retiree plan, the date the Creditable Coverage Notice was distributed and whether or not the creditable coverage status has changed since the last disclosure
- Name, title, and email address of individual authorized to file the Disclosure Notice
- Date of disclosure to CMS
In addition to the annual notice, employers are required to file a disclosure within 30 days after termination of any drug plan and within 30 days after the change in creditable coverage status of any drug plan.
Please contact our Employee Benefits Team if you need help setting up a plan, if you need a plan restated to include the most up to date regulatory requirements or if you have any questions!