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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.
