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Medicare Part D – Creditable Coverage Disclosure to CMS

March 1, 2023 is the deadline for sponsors of calendar year plans to complete an online disclosure form with Centers for Medicare & Medicaid Services (CMS), indicating whether the plan’s prescription drug coverage is creditable or non-creditable. This requirement applies when an employer-sponsored group health plan provides prescription drug coverage to individuals who are eligible for coverage under Medicare Part D.

To determine if the CMS reporting applies, employers should verify whether any of their group health plans cover Medicare-eligible individuals (this includes active post-65 employees and any post-65 spouses). Those that are required to report to CMS should work with their advisors to determine if prescription drug coverage is credible or non-creditable.

Read the Compliance Bulletin, which provides greater detail about the disclosure, timing, and online methods to complete this task.