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

November 20, 2024
Medicare

Changes to Medicare Part D Call for a Reexamination of Creditable Coverage

READ TIME: 5 MINUTES Every year, group health plans are required to notify their Medicare-eligible policyholders whether their prescription drug coverage is “creditable coverage.” Drug coverage is creditable if it is as good or better than the Medicare drug benefit. If a Medicare-eligible individual is not enrolled in creditable coverage, they may incur late enrollment […]
Read more
November 20, 2024
CMS, Compliance Alert

New CMS Rules on Medicare Reporting Penalties

READ TIME: 6 MINUTES The Centers for Medicare & Medicaid Services (CMS) recently issued final rules outlining the penalties for responsible reporting entities (RREs) that fail to meet Medicare Secondary Payer (MSP) reporting obligations. The regulations were applicable as of October 11, 2024, and enforcement will begin in October 2025. The penalties for non-compliance are […]
Read more
October 30, 2024
News

Dear HR Manager

Dear HR Manager, I’ve recently been promoted to a leadership role and want to ensure I’m the best boss I can be. What steps can I take to lead effectively and create a positive environment for my team? – New to Leadership   Dear New to Leadership, Congratulations on your new role! Becoming an outstanding leader […]
Read more
October 15, 2024
HR Elements

Simplifying HR Processes with AI

READ TIME: 4 MINUTES AI is becoming crucial as HR looks to enhance efficiency, streamline processes, and offer personalized solutions. From creating HR materials to improving the recruitment process, AI’s integration is driving a shift in the way organizations support and engage their workforce. According to a recent survey, 44% of employers said they use […]
Read more