Employer’s Prescription Drug Plan Creditable Disclosure Requirement to CMS – Nothing has Changed

October 18, 2011 at 10:34 am | Posted in CMS, Creditable Coverage, Prescription | Leave a comment
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In September we emailed a client alert announcing the new October 15thdeadline for employer plan sponsors to distribute the required annual Medicare Part D Creditable Coverage Notices to their affected employees, retirees, and their dependents.

We received a few calls from clients inquiring about the date for employer plan sponsors to complete the Online Disclosure requirement to the Centers for Medicare and Medicaid Services (CMS) regarding the creditable or non-creditable status of their prospective group health plan’s prescription drug program.  The date of the Online Disclosure requirement has not changed.  Generally, disclosure of the plan’s prescription drug creditable status remains due within 60 days of the beginning of the Plan year. 

Examples of reporting deadlines:

Plan Year Begins Online Due Date to Report to CMS
January 1 March 1
February 1 April 1
March 1 May 1
April 1 June 1
May 1 July 1
June 1 August 1
July 1 September 1
August 1 October 1
September 1 November 1
October 1 December 1
November 1 January 1
December 1 February 1

The only exceptions to the above Online Disclosure requirement are if: (1) the prescription drug program is terminated, or (2) the prescription drug program loses its creditable coverage status. If either of those events were to occur, the employer plan sponsor must provide Online Disclosure to CMS within 30 days of the event’s occurrence.

As always, we welcome the chance to answer any questions about these two distinct employer plan sponsor requirements and deadlines.

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