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Medicare D Disclosure Notice to CMS

Background Information

Each year, employers with health plans that provide prescription drug coverage to Medicare-eligible individuals must disclose to CMS whether that coverage is creditable or non-creditable. This disclosure is required regardless of whether the health plan’s coverage is primary or secondary to Medicare. The annual disclosure must be provided within 60 days after the start of the plan year. For calendar year health plans, the deadline for the 2021 online disclosure is March 1.

What do I have to do?

  1. 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.

  2. The disclosure form lists the required data fields that must be completed in order to generate the disclosure notice to CMS, such as types of coverage, number of options offered, creditable coverage status, period covered by the disclosure notice, number of Part D-eligible individuals covered, etc.

  3. CMS has also provided instructions for detailed descriptions of these data fields and guidance on how to complete the form.

If an employer’s group health plan does not offer prescription drug benefits to any Medicare Part D 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.

Please be advised that Cottingham & Butler does not engage in the practice of law and that information provided is not intended to be construed as legal or tax advice.

Contact us if you have questions!

Cottingham & Butler is committed to continuing to provide our clients with the most current and relevant information. If you have any additional questions regarding the Medicare D Disclosure Notice to CMS, please contact your Cottingham & Butler representative.


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