Each year, sponsors of group health plans must submit an online disclosure form to the Centers for Medicare & Medicaid Services (CMS) to indicate whether their prescription drug coverage is creditable or non-creditable. This requirement applies to employer-sponsored group health plans that offer prescription drug coverage to individuals eligible for Medicare Part D.
CMS Disclosure Deadline
Plan sponsors must complete the online disclosure within 60 days of the plan year’s start. For calendar year health plans, the deadline for submitting the annual online disclosure is March 1, 2025.
In addition to the annual submission, any changes that impact the creditable status of the coverage must be reported to CMS. This must be done within 30 days of any change in the plan’s creditable coverage status or the termination of its prescription drug coverage.
Online Disclosure Process
Plan sponsors are required to use CMS’s online disclosure form, available on the creditable coverage website. This is the only acceptable method of submission unless the entity lacks internet access.
The disclosure form requires specific information, including:
- Types of coverage offered
- Number of available plan options
- Creditable coverage status
- Coverage period
- Number of Part D-eligible individuals covered
- Date of notification to Part D-eligible individuals
- Any changes in the creditable coverage status
CMS has also provided guidance and instructions on how to complete the form.
Next Steps for Employers
To determine whether this CMS reporting requirement applies, employers should assess whether their group health plans cover any Medicare-eligible individuals, such as:
- Active employees
- Disabled employees
- COBRA participants
- Retirees
- Covered spouses and dependents
Employers required to report to CMS should consult with their advisors to confirm whether their prescription drug coverage is creditable or non-creditable. They should also visit the CMS creditable coverage website, which provides access to the online disclosure form and related instructions.