Creditable Coverage Disclosure Deadline and Requirements
Posted on March 1, 2021
The Centers for Medicare and Medicaid Services (CMS) requires employers that offer health plans covering outpatient prescription drugs to complete an online disclosure form 60 days from the start of each health plan year.
Creditable coverage means the group health plan’s prescription drug coverage is actuarially equivalent to Medicare’s Part D drug plans. In other words, the group plan is considered creditable if its drug benefits are as good as or better than Medicare’s benefits.
Deadline for Disclosure: March 1, 2021 for calendar year health plans
All group health plans that include any outpatient prescription drug benefits, regardless of whether the plan is insured, self-funded, grandfathered, or non grandfathered, must complete the CMS disclosure requirement. There is no exception for small employers.
The CMS online tool is the only method allowed for completing the required disclosure.
The entire process usually takes only 5 or 10 minutes to complete. To save time, have the following information handy before you start filling in the form:
- Information about the plan sponsor (employer): Name, address, phone number, and federal Employer Identification Number (EIN).
- Number of prescription drug options offered (e.g., if employer offers two plan options with different benefit levels, the number is “2”).
- Creditable/Noncreditable Offer: Indicate whether all options are creditable or noncreditable or whether some are creditable and others are noncreditable.
- Plan year beginning and ending dates.
- Estimated number of plan participants eligible for Medicare (and how many are participants in the employer’s retiree health plan, if any).
- Date that the plan’s Notice of Creditable (or Noncreditable) Coverage was provided to participants.
- Name, title, and email address of the employer’s authorized individual completing the disclosure.
Click here to access the CMS online tool for the required disclosure.
If you need more information about whether a plan provides creditable coverage or need any other guidance please let me know.