January 17, 2025

Compliance Reminder: CMS Medicare Part D Reporting Due Beginning of March 2025

Employee Benefits

2 min read

Compliance Reminder: CMS Medicare Part D Reporting Due Beginning of March 2025

Employers sponsoring group health plans that provide prescription drug coverage to individuals eligible for Medicare Part D coverage^[1] must annually disclose to the Centers for Medicare and Medicaid Services (CMS) whether that coverage is considered creditable or non-creditable. To be considered creditable, the plan’s drug coverage must be at least actuarially equivalent to Medicare Part D prescription drug coverage.

This reporting requirement^[2] applies to both self-funded and fully insured group health plans and also applies whether the prescription drug coverage is primary or secondary to Medicare.

This annual disclosure must be provided to CMS within 60 days of the start of the plan year, which is typically March 1 (or February 29 for leap years).

For employers with calendar year group health plans, the upcoming deadline to complete this disclosure reporting to CMS is March 1, 2025.

Employers must also complete disclosure reporting to CMS within 30 days following either:

a change in the creditable coverage status of the prescription drug coverage, or
the termination of the plan’s prescription drug coverage.

Online Disclosure to CMS

To complete this CMS disclosure online, click here. For additional CMS guidance and instructions on this reporting requirement, click here.

CMS’s webpage on Creditable Coverage can be accessed here.

Online reporting is the sole method for compliance with the disclosure requirement, unless an employer sponsoring a group health plan does not have internet access.

CMS Disclosure Form Required Data Fields Include:

Details on entity offering coverage such as the employer sponsoring the benefit plan, employer address and phone number, and the employer EIN
Type of coverage
Number of prescription drug options offered
Creditable coverage status
Period covered by the disclosure notice (plan year)
Number of Part D-eligible individuals covered
Date the creditable coverage disclosure notice is provided to Part D-eligible individuals
Change in creditable coverage status, if applicable

Medicare Part D Creditable Coverage Notice

Please note that this annual disclosure reporting to CMS is different from the requirement to provide Part D-eligible individuals with a notice disclosing the creditable status of the plan’s prescription drug coverage by October 15 of each year (coinciding with the annual Medicare Part D enrollment period).

Click here for more details on the October 15 notice distribution deadline and also how to determine a group health plan’s prescription drug coverage creditable status.

Employer Action

Employers with calendar year plans are advised to take action now and complete the online disclosure reporting to CMS by the deadline of March 1, 2025.

Contact your Risk Strategies account team members for assistance or contact us directly here.

[1] Includes Medicare-eligible employees, retirees, spouses, or dependents.

[2] Group health plans that do not provide prescription drug coverage to any Medicare Part D eligible individuals as of the beginning of the plan year are not subject to this CMS reporting requirement for that plan year.

The contents of this article are for general informational purposes only and Risk Strategies Company makes no representation or warranty of any kind, express or implied, regarding the accuracy or completeness of any information contained herein. Any recommendations contained herein are intended to provide insight based on currently available information for consideration and should be vetted against applicable legal and business needs before application to a specific client.

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