Group health plan sponsors who offer prescription drug benefits to any Medicare-eligible individual are required to disclose to CMS whether their prescription drug coverage is creditable or non-creditable. This disclosure is required whether the health plan’s coverage is primary or secondary to Medicare.
The plan sponsor must complete the online disclosure within 60 days after the beginning of the plan year. For calendar year health plans, the deadline for the annual online disclosure is March 1, 2018.
Plan sponsors are required to use the online disclosure form on the CMS Creditable Coverage webpage. This is the sole method for compliance with the disclosure requirement, unless the entity does not have Internet access. CMS has also provided instructions for detailed descriptions of these data fields and guidance on how to complete the form.
If a group health plan does not offer outpatient prescription drug benefits to any Medicare-eligible individuals as of the beginning of the plan year, the group health plan is not required to submit the online disclosure form to CMS for that plan year.
For questions about your health plan’s Medicare D creditable status or other required disclosures, contact your NEEBCo representative.