The deadline to complete the Medicare Part D disclosure for employers who offer group Medical and Prescription drug coverage to their employees was February 29. The Medicare Part D online disclosure form must be completed within 60 days of the start to the medical plan year; for calendar plan years, this was historically March 1, however since 2020 is a leap year, the completion deadline for the online disclosure was February 29, 2020. Employers are required to complete the form by visiting Centers for Medicare & Medicaid Services (CMS) website, populate the required company information, and confirm whether their group health coverage is credible or not credible as compared to Medicare Part D.
Generally, there are no specific penalties for employers who fail to complete the Medicare Part D disclosure form, except for employers who are claiming the Retiree Drug Subsidy, if these employers who receive this subsidy do not complete the Medicare Part D disclosure form, it will result in the subsidy being discontinued. The Retiree Drug Subsidy is a program offered by CMS to reimburse health plan sponsors a portion of their eligible expenses for retiree prescription drug benefits. However, for those who do not receive the Retiree Drug Subsidy, there could be other adverse effects down the road for not completing the disclosure—primarily from employees who want the assurance that their prescription drug plan is creditable.
Contact your Cowden representative for more information on this or other compliance issues.