Employers sponsoring a group health plan with prescription drug benefits are required to notify their Medicare-eligible participants and beneficiaries as to whether the prescription drug coverage provided under the plan is “creditable” or “non-creditable.” This notification must be provided prior to October 15th each year.
Also, following the plan’s annual renewal, the employer, as the entity responsible for submitting the required disclosure, must notify the Centers for Medicare & Medicaid Services (“CMS”) of the creditable status of the prescription drug plan. Please see detailed information below on how to submit the notification to CMS.
In order to provide this information, employers must access CMS’s online reporting system at:https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html.Click on the CMS Disclosure Form button and complete and submit the required information
As a reminder, notice must be provided by the following deadlines:
- Within 60 days after the beginning date of each plan year;
- Within 30 days after the termination of the prescription drug plan; and
- Within 30 days after any change in the creditable coverage status of the prescription drug plan.
For example, an employer with a calendar year plan (January 1 – December 31, 2025) must complete this reporting no later than March 1, 2025.
If there was a change in the creditable coverage status of a prescription drug plan offered by the employer (e.g., from creditable to non-creditable, or vice versa), notice should be provided to CMS within 30 days of the change. For example, if a change occurred in connection with the January 1, 2025 plan year, CMS should be notified by January 31, 2025.
Employer Action
- For calendar year 2025 plans, timely complete reporting with CMS. For non-calendar year plans, timely complete reporting with CMS following the start of your 2025 plan year.
- You will need to have the following information ready to include when you complete the CMS online reporting:
- The creditable (or non-creditable) status of prescription drug coverage provided by all plan options available to employees.
- The date that the annual creditable (or non-creditable) coverage notice was furnished to Part D eligible individuals. You may have included this notice with open enrollment materials or sent it following the start of the plan year.
- An estimate of the number of Medicare Part D eligible individuals covered under the plan. This does not have to be an exact number.
Additional resources for completing the form are available at:
- Disclosure to CMS Guidance and Instructions: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosure.html
- Disclosure to CMS Form User Guide with screenshots: https://www.cms.gov/medicare/prescription-drug-coverage/creditablecoverage/downloads/ccuserguide.pdf
As always, please do not hesitate to contact your Brooks Financial Group Advisor for questions and support.
Thank you,
The Brooks Financial Group Team