Each year, employer-sponsored health plans that offer any type of prescription drug coverage to Medicare eligible individuals must disclose if the coverage offered is as generous as the standard Part D drug plan (“Creditable”) or not.
Deadlines for Disclosure:
- To Medicare Eligible Individuals: Annually before* October 15 (and at other and at other prescribed times, including upon request or whenever prescription drug coverage ends).
- To CMS: No later than 60 days from the beginning of each plan year.
*“Before” is defined by CMS guidance as within the past 12 months. Therefore, employers can satisfy the Oct. 15 individual disclosure requirement by providing a notice to all plan participants annually, such as during open enrollment.
Please note: Marshall & Sterling clients are contacted at renewal each year with individual Creditable Coverage information and detailed instructions for meeting their annual compliance obligations.