February 23, 2015
Plan sponsors are required to disclose to the Centers for Medicare & Medicaid Services (CMS) whether their prescription drug coverage is creditable. The disclosure must be made to CMS on an annual basis, or upon any change that affects whether the coverage is creditable.
At a minimum, the CMS creditable coverage disclosure notice must be provided at the following times:
For plan sponsors with calendar year plans, the deadline to comply with the annual disclosure requirement is March 1, 2015. Because March 1, 2015 falls on a Sunday, CMS may extend the disclosure deadline to Monday, March 2, 2015. However, CMS has not yet made this announcement. Thus, plan sponsors should plan on completing the online disclosure form by March 1, 2015.
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.
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, date the creditable coverage disclosure notice is provided to Part D-eligible individuals, and change in creditable coverage status. CMS has also provided instructions for detailed descriptions of these data fields and guidance on how to complete the form.
The online disclosure form is available at https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html.
Detailed instructions are available at https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/Downloads/CreditableCoverageDisclosureUserManual05292012.pdf.
For additional information, please contact your Burnham Benefits Consultant, Burnham Benefits at 949-833-2983, or firstname.lastname@example.org.