Medicare Part D Creditable Coverage Notice Deadline

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.  

For more information, click here to watch the Creditable Coverage Reporting episode from our "Compliance Minute" video series.