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Medicare Part D Disclosures due by March 1, 2018 for Calendar Year Plans

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Employers who sponsor group health plans that provide prescription drug coverage must complete an online disclosure to CMS (Centers for Medicare & Medicaid Services) certifying whether their prescription drug coverage is creditable or non-creditable.

The disclosure must be made to CMS on an annual basis or whenever a change occurs to the group health plan’s prescription drug coverage that affects the creditability of the plan. The Medicare Part D disclosure notice must be made during the instances below:

  • Within 60 days after the beginning of the plan year (renewal, contract year, etc.) for which the employer is providing the disclosure to CMS
    • For group health plans that begin January 1st disclosure must be made by March 1st (For example, plans beginning January 1, 2018 must disclose to CMS by March 1, 2018)
    • For non-calendar year health plans, disclosure is due within 60 days from the beginning of the plan year (For example, plans beginning May 1st must disclose to CMS by July 1st)
  • Within 30 days after the termination of a plan’s prescription drug coverage; and
  • Within 30 days after any change in the plan’s creditable coverage status

Employers are also required to disclose to individuals who are eligible for Medicare Part D coverage whether the plan’s prescription drug coverage is creditable or non-creditable. This notice must be distributed each year before October 15th and other times throughout the year based upon certain events. It is best practice to distribute this notice to all plan participants as it may be difficult for an employer to know who is eligible for Medicare Part D coverage (these individuals may include active employees, employees on leave, retirees, dependents and COBRA continuants). The best practice is to include this notice in annual open enrollment materials and to provide it new hires throughout the year with documentation that the notice was provided.

What Employers Need to Know

Employers should work with their carriers/TPA/PBM/actuaries to verify if their group health plans offer creditable or non-creditable prescription drug coverage. Employers should visit CMS’ website to complete their disclosure within the requisite timeframes. CMS’ website also includes links to their disclosure form, instructions, and model notices.

Click here for additional information.