Don’t Overlook Prescription Drug Reporting to CMS - Bim Group

Don’t Overlook Prescription Drug Reporting to CMS

READ TIME: 2 MINUTES

Each year, a bright light is cast on providing individuals with annual Medicare Part D notices detailing the creditable status of their employer-provided prescription drug coverage. Lurking in the shadows is another annual requirement: reporting to the Centers for Medicare & Medicaid Services (CMS) whether the prescription drug coverage is creditable or not. These tips will help employers better understand this lesser[1]known Medicare Part D compliance obligation.

When

Plan sponsors must input their disclosures to CMS every year, no later than 60 days following the start of a new plan year. Thus, calendar year plan sponsors must report their plans’ creditable status by March 1. Plan sponsors also must alert CMS within 30 days after terminating the prescription drug plan or coverage, or if the creditable status changes.

How

Plan sponsors must use CMS’s creditable coverage portal to complete and file the necessary creditable coverage disclosure form. CMS offers no paper alternative to satisfy this disclosure requirement absent one of a few rare and limited exceptions. The good news is that the CMS portal includes helpful hyperlinks to agency guidance and simple step-by-step instructions.

Conclusion

It is easy to forget creditable coverage reporting during the hectic ACA and W-2 reporting season. Also, HR professionals tend to be swamped with participant inquiries at the outset of a new plan year, so it can be easy to miss a basic compliance obligation like creditable coverage reporting. Plan sponsors with calendar year plans should set a reminder each year to ensure they complete this task by March 1

This information has been prepared for UBA by Fisher & Phillips LLP. It is general information and provided for educational purposes only. It is not intended to provide legal advice. You should not act on this information without consulting legal counsel or other knowledgeable advisors.

Recent Insights

April 8, 2024
HIPAA

Timely Responses Required for Requests under HIPAA’s Right of Access Rule

READ TIME: 4 MINUTES On December 15, 2023, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR), announced a settlement under the Health Insurance Portability & Accountability Act (HIPAA) Right of Access Rule. This penalty illustrates that the Right of Access Rule remains a focus of HHS and that health […]
Read more
April 8, 2024
Compliance Alert

March 2024 Compliance Recap

READ TIME: 7 MINUTES ACA reporting is in its first year of the required electronic reporting for employers filing ten or more returns annually. Employers and employees must make changes to HSAs by the April 15 deadline. Employers of all sizes continued to prepare for the June 1 RxDC Reporting using the newly released instructions. […]
Read more
March 27, 2024
HR Elements

Workplace Culture | Attracting and Hiring Veterans

READ TIME: 5 MINUTES Hiring veterans can address the challenges of a skilled labor shortage and diversify your talent pool. You can tap into veterans’ technical skills and leadership experience by adjusting your recruitment strategies to consider practical experience over academic qualifications. Why should you develop a more inclusive recruitment strategy for veterans? Veterans bring […]
Read more
March 18, 2024
News

Bim Group named one of the 2024 Best Places to Work in Kentucky!

Bim Group is honored to be named a Best Place to Work (BPTW) in Kentucky for the 19th year in a row! It truly never gets old and we are extremely proud of our perennial recognition as a “Best Place to Work” employer – a designation bestowed on our company by our employees. We have a unique […]
Read more