Group health plan sponsors who provide prescription drug coverage to individuals who are eligible for coverage under Medicare Part D, are required to complete an online disclosure form with the Centers for Medicare & Medicaid Services (CMS).
The plan sponsor must complete the online disclosure within 60 days after the beginning of the plan year. As this year is a leap year, the deadline for the annual disclosure is February 29, 2020.
Medicare Part D Disclosure
Group health plan sponsors are required to disclose to CMS whether their prescription drug coverage is creditable or non-creditable. This disclosure is required regardless of whether the health plan’s coverage is primary or secondary to Medicare.
When a plan’s design is not eligible for the simplified method, an actuarial determination must be made.
How to Determine Creditability
A group health plan’s prescription drug coverage is considered creditable if its actuarial value equals or exceeds the actuarial value of the Medicare Part D prescription drug coverage. Employers with insured plans should ask their health insurance carriers if they have made this determination for the insured product.
This determination measures whether the expected amount of paid claims under the group health plan’s prescription drug coverage is at least as much as the expected amount of paid claims under the Part D prescription drug benefit.
The disclosure must be made to CMS on an annual basis and whenever any change occurs that affects whether the coverage is creditable. The Medicare Part D disclosure must be provided within:
- 60 days after the beginning date of the plan year for which the entity is providing disclosure to CMS;
- 30 days after the determination of the plan’s prescription drug coverage; and
- 30 days after any change in the plan’s creditable coverage status.
Plan sponsors are required to use the online disclosure form on the CMS creditable coverage website. This is the sole method for compliance with the disclosure requirement. CMS has provided model disclosure notices to use when disclosing their coverage status here.
For more information on the disclosure, click here.
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